SCIENTinC INTEGRITY AND PUBUC TRUST: THE SCIENCE B&
HIND FEDERAL POUCIES AND MANDATES: CASE STUDY 1-
STRATOSPHERIC OZONE: MYTHS AND REALITIES
Y 4. SCI 2:104/31
Scientific Integrity and Public Tro...
ANG
BEFORE THE
SUBCOMMITTEE ON
ENERGY AND ENVIRONMENT
OF THE
COMMITTEE ON SCIENCE
U.S. HOUSE OP REPRESENTATIVES
ONE HUNDRED FOURTH CONGRESS
FIRST SESSION
SEPTEMBER 20, 1995
[No. 31]
Printed for the use of the Committee on Science
SCIENTinC INTEGRTTY AND PUBUC TRUST: THE SCIENCE
BEHIND FEDERAL POUCIES AND MANDATES: CASE STUDY
1-STRATOSPHERlC OZONE: MYTHS AND REALITIES
HEARING
BEFORE THE
SUBCOMMITTEE OX
ENERGY AND EMIROXMEXT
OF THE
COMMITTEE ON SCIENCE
U.S. HOUSE OF REPRESENTATIVES
ONE HUNDRED FOURTH CONGRESS
FIRST SESSION
SEPTEMBER 20, 1995
[No. 31]
Printed for the use of the Committee on Science
U.S. GOVERNMENT PRINTING OFFICE
20-413 WASHINGTON : 1996
For sale by the U.S. Government Printing Office
Superintendent of Documents, Congressional Sales Office, Washington, DC 20402
ISBN 0-16-052519-5
COMMITTEE ON SCIENCE
ROBERT S. WALKER, Pennsylvania, Chairman
F. JAMES SENSENBRENNER, Jr.,
Wisconsin
SHERWOOD L. BOEHLERT, New York
HARRIS W. FA WELL, Illinois
CONSTANCE A. MORELLA, Maryland
CURT WELDON, Pennsylvania
DANA ROHRABACHER, California
STEVEN H. SCHIFF, New Mexico
JOE BARTON, Texas
KEN CALVERT, California
BILL BAKER, California
ROSCOE G. BARTLETT, Maryland
VERNON J. EHLERS, Michigan 2
ZACH WAMP, Tennessee
DAVE WELDON, Florida
LINDSEY O. GRAHAM, South Carolina
MATT SALMON, Arizona
THOMAS M. DAVIS, Virginia
STEVE STOCKMAN, Texas
GIL GUTKNECHT, Minnesota
ANDREA H. SEASTRAND, California
TODD TIAHRT, Kansas
STEVE LARGENT, Oklahoma
VAN HILLEARY, Tennessee
BARBARA CUBIN, Wyoming
MARK FOLEY, Florida
SUE MYRICK, North Carolina
David D. Clement, Chief of Staff and Chief Counsel
Barry Beringer, General Counsel
TiSH Schwartz, Chief Clerk and Administrator
Robert E. Palmer, Democratic Staff Director
GEORGE E. BROWN, Jr., California RMM i
RALPH M. HALL, Texas
JAMES A. TRAFICANT, Jr., Ohio
JAMES A. HAYES, Louisiana
JOHN S. TANNER, Tennessee
PETE GEREN, Texas
TIM ROEMER, Indiana
ROBERT E. (Bud) CRAMER, Jr., Alabama
JAMES A. BARCIA, Michigan
PAUL McHALE, Pennsylvania
JANE HARMAN, California
EDDIE BERNICE JOHNSON, Texas
DAVID MINGE, Minnesota
JOHN W. OLVER, Massachusetts
ALCEE L. HASTINGS, Florida
LYNN N. RIVERS, Michigan
KAREN McCarthy, Missouri
MIKE WARD, Kentucky
ZOE LOFGREN, California
LLOYD DOGGETT, Texas
MICHAEL F. DOYLE, Pennsylvania
SHEILA JACKSON-LEE, Texas
WILLIAM P. LUTHER, Minnesota
Subcommittee on Energy and Environment
DANA ROHRABACHER, CaUfornia, Chairman
HARRIS W. FAWELL, Illinois
CURT WELDON, Pennsylvania
ROSCOE G. BARTLETT, Maryland
ZACH WAMP, Tennessee
LINDSEY O. GRAHAM, South Carolina
MATT SALMON, Arizona
THOMAS M. DAVIS, Virginia
STEVE LARGENT, Oklahoma
BARBARA CUBIN, Wyoming
MARK FOLEY, Florida
STEVEN H. SCHIFF, New Mexico
BILL BAKER, California
VERNON J. EHLERS, Michigan
STEVE STOCKMAN, Texas
ROBERT S. WALKER, (PA) (ex-officio)
JAMES A. HAYES, Louisiana
DAVID MINGE, Minnesota
JOHN W. OLVER, Massachusetts
MIKE WARD, Kentucky
MICHAEL F. DOYLE, Pennsylvania
TIM ROEMER, Indiana
ROBERT E. (Bud) CRAMER, Jr., Alabama
JAMES A. BARCU, Michigan
PAUL McHALE, Pennsylvania
EDDIE BERNICE JOHNSON, Texas
LYNN N. RIVERS, Michigan
KAREN McCarthy, Missouri
GEORGE E. BROWN, Jr., (CA) (ex-officio)
1 Ranking Minority Member
2 Vice Chairman
(II)
CONTENTS
WITNESSES
September 20, 1995: Page
Hon. John T. Doolittle, Representative in Congress of the United States
from the 4th District of California 13
Hon. Tom DeLay, Representative in Congress of the United States from
the 22d District of Texas 20
Panel 1:
Robert T. Watson, Associate Director of Environment, Office of Science
and Technology Policy, Executive Office of the President, Washington,
DC 30
Dr. S. Fred Singer, president, the Science and Environmental Policy
Project, Fairfax, VA 50
Dr. Daniel L. Albritton, Director, Aeronomy Laboratory, Environmental
Research Laboratories, NOAA, Boulder, CO 65
Dr. Sallie Baliunas, senior scientist, the George C. Marshall Institute,
Washington, DC 123
Dr. Richard Setlow, Associate Director, Life Sciences, Brookhaven Na-
tional Laboratory, Upton, NY 133
Dr. Margaret L. Kripke, professor and chairman, department of immunol-
ogy. University of Texas, M.D. Anderson Cancer Center, Houston, TX ... 145
Panel 2:
Hon. Mary Nichols, Assistant Administrator for Air and Radiation, Envi-
ronmental Protection Agency, Washington, DC 189
Kevin Fay, Alliance for Responsible Atmospheric Policy, Arlington, VA .... 203
Ben Lieberman, environmental research associate. Competitive Enter-
prise Institute, Washington, DC 226
Dr. Richard L. Stroup, senior associate. Policy Economy Research Center,
Bozeman, MT 263
Dr. Dale K. Pollet, project leader, entomology, Louisiana Cooperative
Extension Service, Baton Rouge, LA 271
APPENDIX
Appendix 1 — Statements for the record:
Opening statement submitted by the Hon. James E. Hayes, Representa-
tive in Congress of the United States from the 7th District of Louisi-
ana, and ranking Democratic member, Subcommittee on Energy and
Environment 293
Statement submitted by the Hon. Henry A. Waxman, Representative
in Congress of the United States from the 29th District of California .... 296
Statement submitted by Rafe Pomerance, Deputy Assistant Secretary
of State, U.S. Department of State 298
Appendix 2 — Questions and answers for the record:
Dr. S. Fred Singer 307
Appendix 3 — Additional materials for the record:
Remarks by Dr. John H. Gibbons, Assistant to the President for Science
and Technology, "Sound Science, Sound Policy: The Ozone Story," Uni-
versity of Maryland at College Park, September 19, 1995 311
Letter dated October 11, 1995, to the Hon. Dana Rohrabacher, Chairman,
Subcommittee on Energy and Environment, by Dr. Robert T. Watson,
Associate Director for Environment, Office of Science and Technology
Policy 320
(III)
IV
Page
Appendix 3 — Additional materials for the record — Continued
Letter dated October 19, 1995, to the Hon. Dana Rohrabacher, Chairman,
Subcommittee on Energy and Environment, by Dr. Sallie Baliunas,
senior scientist, George C. Marshall Institute 324
Letter dated November 15, 1995, to Sir John Maddox, editor, Nature,
by the Hon. George E. Brown, Jr., ranking Democratic member, Com-
mittee on Science 336
Letter dated November 17, 1995, to the Hon. George E. Brown, Jr.,
ranking Democratic member. Committee on Science, by Sir John Mad-
dox, editor. Nature 338
Letter dated December 18, 1995, to the Hon. George E. Brown, Jr.,
ranking Democratic member, Committee on Science, by Dr. Sallie
Baliunas, senior scientist, George C. Marshall Institute 343
Associated Press article dated May 1, 1992, entitled '"Ozone hole' fails
to materialize as feared, NASA says" 347
Enclosures to letter dated September 18, 1995, to the Hon. George E.
Brown, Jr., ranking Democratic member. Committee on Science, by
Rex A. Amonette, M.D., president, American Academy of Dermatology .. 348
SCIENTIFIC INTEGRITY AND PUBLIC TRUST:
THE SCIENCE BEHIND FEDERAL POLICIES
AND MANDATES
CASE STUDY 1— STRATOSPHERIC OZONE:
MYTHS AND REALITIES
WEDNESDAY, SEPTEMBER 20, 1995
House of Representatives,
Committee on Science,
Subcommittee on Energy and Environment,
Washington, DC.
The Subcommittee met at 9:37 a.m., in room 2318 of the Ray-
burn House Office Building, the Honorable Dana Rohrabacher,
Chairman of the Subcommittee on Energy and Environment, pre-
siding.
Mr. Rohrabacher. The hearing of the Energy and Environment
Subcommittee will come to order.
And Mr. DeLay will be here momentarily. Mr. Doolittle is here
already and they will have testimony for us in the beginning.
But first, I will begin with an opening statement.
I am Congressman Dana Rohrabacher, Chairman of the Commit-
tee.
On February 3, 1992, then-Senator Al Gore told the United
States Senate that, and I quote, "If atmospheric conditions con-
tinue as they are for a few weeks, there could be an ozone hole
above heavily-populated areas in the northern hemisphere. There
could well be an ozone hole above Kennebunkport."
And I remember that time period very well because I remember
the Senator coming to one of the hearings that we had for the
science hearings with many cameras in tow and newsmen in tow,
in which he made the same prediction.
But on the Senate floor, he went on to predict that there would
be, and I remember, I believe he made the same predictions here
with us, that there would be 300,000 additional — that's addi-
tional— skin cancer deaths in the United States. And he envisioned
a future in which children would have to hide from the sun when
out to play.
We now know that the hole in the sky over Kennebunkport was
bunk.
I have a little headline here for you, which, a few months after
Senator Gore was before our committee, predicting the hole, the
newspaper headline reads: "Ozone Hole Fails to Materialize as
Feared."
(1)
Well, we now know that the hole in the sky over Kennebunkport
was bunk. We can see it. We can analyze it. And this hole epi-
sode— and there may be a pun intended, I don't know — turned out
to be another, basically "the-sky-is-falling" cry from an environ-
mental Chicken Little, a cry we've heard before when the American
people were scared into the immediate removal of asbestos from
their schools, which turned out to be exactly the wrong method and
the wrong way of going about to tackle the problem, and when the
American people stopped eating apples, causing millions and mil-
lions of dollars' worth of loss to apple farmers because they were
afraid of Alar.
This time, the scare-mongers managed to stampede the Congress
and the President of the United States. President Bush sped up
what had been a deliberate timetable to phase out CFCs around
the world.
But that wasn't good enough. The U.S. unilaterally imposed an
onerous excise taix on CFCs which has, as it always does, led to a
thriving black market, which is what we see in the United States
today.
In July of this year, a senior U.S. Customs agent called bootleg
CFCs, "almost as profitable as dope."
As this funny circus goes on, we have to ask ourselves — does the
science justify the actions that have been taken and the billions
that have been spent? Instead of maintaining a deliberate pace, our
country rushed head-long to ban the substances people rely on to
cool their homes, their cars, and their refrigerators to keep fruits
and vegetables and other food fresh.
Was this justified by science?
Even if we accept the premise that these chemicals are harmful
to the stratospheric ozone layer, what is the actual risk of, say, ex-
tending the phase-out period of CFCs in vehicles, as compared to
the impact on the American consumer faced with replacing such
expensive equipment?
Are we getting objective science from our regulatory agencies, or
are scientists with unconventional views being shut out of the proc-
ess?
These are some of the issues that will be aired at this, the first
of a series of hearings on scientific integrity and the public process.
Contrary to what you might have heard, this hearing is not going
to be about whether we are for or against skin cancer. The Amer-
ican people deserve better of their government than scare tactics
that are designed to intimidate and repress rational discussion.
During the course of these hearings, this Subcommittee will air
views that are politically correct and politically incorrect. We will
take a close look at the science behind regulations which govern-
ment officials and the media have presented largely in emotional
terms, and we will hear from both sides equally — I want to repeat
that — we will hear from both sides equally, and I am hoping today
to promote a dialogue between the various points of view, rather
than just trying to have one view prevail over the other or trying
to schedule one view early on in the hearing and not letting the
other view be heard until the very end of the hearing, which far
too often in the past was modus operandi for the congressional
committees.
For today's hearing, we are pleased that some of the most promi-
nent scientific and economic experts on stratospheric ozone have
agreed to testify.
With this, I will now turn and ask my esteemed colleague, who
I have great respect for, who chaired the overall Science Committee
for a number of years, and now is with us, gracing us with his
presence and his expertise, former Chairman Brown.
Would you like to make an opening statement?
Mr. Brown. I appreciate the Chairman's courtesy in allowing me
the privilege of making an opening statement. I'm really substitut-
ing here for the Ranking Minority Member, Congressman Hayes,
who couldn't be present, but will, I hope, present a statement.
Let me first say that I, as you do, welcome these hearings. What
we badly need for all of science in this country is a better public
understanding of the basis on which science is conducted and the
basis on which regulatory decisions are made based upon that
science.
And I will compliment the Chairman for the way in which he has
phrased the question and on his fairness in terms of setting up a
hearing in which we do have good representatives of both sides
who are appearing and making their case.
And I hope that we can publicize the results of this hearing in
such a way that it will contribute to the understanding of the
American people on how science policy and science regulatory mat-
ters are conducted.
And they have been flawed in the past. I would be the first to
agree with that.
I note with some interest the Chairman's opening statement
about the Vice President and Senator Gore's statement and I will
admit that that was an effort to focus attention, in a very highly
visible way, on an issue which the Senator turned out to be slightly
exaggerating the consequences.
Now if he were the first politician that had ever done that, I
would feel that we might have a case here. But that rather typi-
cally represents the way that politicians go about getting interest
focused on an issue which they are concerned with.
The process today is how we really need to hold hearings and to
prepare the basis for legislation in a sounder and longer-term way.
And I say this without intending to criticize the Vice President.
I watched with great admiration as he exploited every opportunity
to focus public attention on science issues while he was a member
of this Committee. He did it in a good way and I think that Mr.
Rohrabacher is doing a very good job in trying to perhaps now
bring about a broader-based view on how some of these things are
done.
So, Mr. Chairman, I welcome the hearing. This is a very impor-
tant issue. The global warming issue is one that we will be in-
volved in through both policy and appropriations. We're into the
level of billions of dollars per year in the area of atmospheric
science and it's only appropriate that we act with great prudence
with regard to that, with regard to ozone, yes.
It's my personal feeling that the scientific case for ozone deple-
tion is by now extremely strong, if not overwhelming. Of course,
this will be explored by the witnesses that we have before us.
If there ever was a way in which, an example of how good science
was developed, I think the ozone issue illustrates that process.
I might say that our history of concern for ozone depletion goes
back at least a full generation when it was one of the issues that
came up in connection with our discussion of whether to develop
a fleet of supersonic aircraft, probably 20-odd years ago. And it was
thought at that time that the aircraft would destroy the ozone
layer and cause the problems that we now blame on
chlorofluorocarbons.
That proved to be a slight exaggeration. We never put up the
fleet of supersonic transport. But it was not because of their impact
on the ozone layer. It was the impact on our pocketbooks which we
were worried about.
Mr. Chairman, I will ask unanimous consent that my full state-
ment be put into the record at this point.
Mr. ROHRABACHER. Without objection.
[The full statements of Subcommittee Chairman Rohrabacher
and Ranking Minority Member Brown follow:]
Opening Statement, Hearing on Ozone Depletion, September 20, 1995
On February 3, 1992, then Senator Al Gore told the U.S. Senate that "if atmos-
pheric conditions continue as they are for a few weeks, there could be an ozone hole
above heavily populated areas of the northern hemisphere. . . . There could well be
an ozone hole above Kennebunkport."
Senator Gore then went on to predict 300,000 additional skin cancer deaths in the
United States and envisioned a future in which children would have to hide from
the sun in the when out at play.
We now know that "the hole in the sky over Kennebunkport" was bunk.
On May 1, the headlines read, "OZONE HOLD FAILS TO MATERIALIZE."
This whole episode (no pun intended) turned out to be another cry that "the sky
is falling" from an environmental chicken little — a cry we've heard before when the
American people were scared into immediate removal of asbestos from schools and
stopped eating apples because of Alar.
This time they managed to scare the President of the United States.
President Bush sped up what had been a deliberate timetable to phase out CFCs
around the world.
But that wasn't good enough. The U.S. unilaterally imposed an onerous excise tax
on CFCs which has, as it always does, led to a thriving black market.
In July, a senior U.S. Customs Agent called bootlegged CFCs "almost as profit-
able as dope."
Does the science justify the actions that have been taken and the billions that
have been spent?
Instead of maintaining a deliberate pace, our country rushed headlong to ban the
substances people rely on to cool their homes, cars and refrigerators. Is this justified
by the science?
Even if we accept the premise that these chemicals are harmful to the strato-
spheric ozone layer, what is the actual risk of, say, extending the phase out of CFCs
in vehicles, compared to the impact on the American consumer faced with replacing
expensive equipment?
Are we getting objective science from our regulatory agencies or are scientists
with unconventional views shut out of the process?
These are some of the issues that will be aired at this first of a series of hearings
on "Scientific Integrity and the Public Process."
Contrary to what you might hear today, this hearing is not about being for or
against skin cancer. The Ajnerican people deserve better from their government
than scare tactics designed to intimidate and repress rational discussion.
During the course of these hearings, this subcommittee will air views politically
correct and incorrect.
We will take a close look at the science behind regulations which government offi-
cials and the media have presented largely in emotional terms and hear from both
sides equally.
For today's hearing, we are pleased that some of the most prominent scientific
and economic experts on the stratospheric ozone issue have agreed to testify.
Opening Statement by the Honorable George E. Brown, Jr.
accelerated phaseout of stratospheric ozone depletion substances
Mr. Chairman, I welcome today's hearing as an opportunity to set the record
straight on the issue of ozone depletion and the Montreal Protocol. This is perhaps
one of the most important success stories that we have on how "good science" has
been transformed into "good policy".
By any measure imaginable, there now exists a true consensus regarding the
science of ozone depletion. Research in the U.S. and other countries supported by
both the industry and Government has provided policy makers with a base of knowl-
edge that underlies some of the most sophisticated cost-benefit analyses ever cairried
out. Today, the science is even stronger than when the original Montreal Protocol
was signed.
The results we will hear today should provide ample proof that the Montreal Pro-
tocol has worked. The Government and industry, acting together, have averted the
dire scenarios that dominated the headlines a decade ago. Moreover, we can point
with pride to the international leadership role we have developed in this area.
Finally, while several issues remain, the transition to substitutes has gone
smoothly with no major economic dislocations. To be certain, some individuals will
feel the pinch — higher future costs for CFCs, diminishing availability of stockpiles,
higher maintenance costs for old equipment and so on.
Many of us who own Beta format VCRs, 33V3 RPM records, and typewriters have
experienced these same frustrations. While I do not mean to trivialize the cases we
will hear, they should be factored into an overall cost-benefit framework and should
not, by themselves, drive public policy. An analysis of costs alone provides a dis-
torted and one-sided picture of the effects of the phase-out of CFCs.
I am mindful, of course, that some in Congress will be seeking to reverse the
progress that has been made in phasing out ozone depleting chemicals and even
abandon our international commitments altogether. I strongly feel that this would
be a tragic and irresponsible mistake.
I want to commend the Chairman for working with us to structure a balanced
hearing today and I am confident that all points of view will be aired. We have in-
vited representative voices from the overwhelming scientific consensus that has
helped us understand the atmospheric dynamics associated with CFCs. Of course,
the reality is that there are skeptics regarding ozone depletion — and we have in-
vited some of the most prominent of those skeptics here today.
I beUeve there is a place for such skeptics. Their challenges can provide intellec-
tual stimulation and they can perform a valuable role in keeping the science "hon-
est". I would hope though, that at the end of the day, our public policy is based on
the predominant view, the peer reviewed science, and the international consensus.
I do not believe any other rational path exists.
Congress, as an institution, lacks scientific expertise to make judgements between
competing claims. The only source of internal science advice to Congress, the Office
of Technology Assessment, is being exterminated as a budget saving move. Given
this situation, we cannot responsibly choose to follow the guidance of the scientific
fringe — no matter how intriguing and no matter how much their message may fit
with our own preferences and prejudices.
I will close by reminding my colleagues that we have come a long way in develop-
ing the international consensus on ozone depletion. U.S. leadership in this area has
been supported by three Administrations. U.S. negotiators will be meeting again
this October to review the progress we have made. I hope that we will take a re-
sponsible view here today and provide our side with the support they will need in
carrying out these important talks.
I would like to insert into the record a letter we received from the American Acad-
emy of Dermatology regarding the relationship between ozone depletion and skin
cancer. I believe my colleagues will find it compelling. I look forward to the testi-
mony of our other witnesses here today.
6
Mr. Brown. Furthermore, I would like to include as a part of my
statement a letter we received from the American Academy of Der-
matology regarding the relationship between ozone depletion and
skin cancer. (See Appendix 3 for enclosures.)
The American Academy of Dermatology, of course, includes those
medical professionals who deal most with the issue of skin cancer
and their statement should have considerable weight because of
that.
Mr. ROHRABACHER. That will be included, without objection.
Mr. Brown. And two additional matters. I would like that the
statement of our colleague, Henry Waxman, who could not be
present, be included in the record. (See Appendix 1.)
He is currently involved in the Clean Air Act and could not be
here because of that.
Mr. ROHRABACHER. Without objection, it will be put in the
record.
Mr. Brown. And furthermore, a statement by the science advisor
to the President on ozone depletion, Dr. Jack Gibbons. (See Appen-
dix 3.)
Mr. ROHRABACHER. That will be put in the record, without objec-
tion, as well.
[The information follows:]
InnD: American Academy of Dermatology
1350 1 Street. N.W.. Sun e 880
Washinctton, DC. 2000S-33I9
ii\KiH2/»42..VVS,^
V >(1>/X42-1.(^S
\iirl'miilnl-h.l„l
September 18, 1995
The Honorable George E. Brown, Jr.
Ranking Democratic Member
Committee on Science
U.S. House of Representatives
2320 Raybura House Office Building
Washington, DC 20515-6301
Dear Congressman Brown:
On behalf of Ae American Academy of Dermatology, 1 am pleased to respond to your
September 13 letter requesting the Academy's views on "the relationship between UV
radiation and the various fonns of malignant and non-malignant skin cancer. " As you know,
the Academy is dedicated to educating Americans about the dangers of skin cancer. Over
tfie past decade, dermatologists have conducted free skin cancer screening clinics, screened
over 1 miUion Americans, distributed thousands of skin cancer booklets and bookmarks, and
conducted a concerted public information campaign to alert the American people to the
dangers of the sim's rays.
1 cannot understate the seriousness of the skin cancer problem. Today, skin cancer is the
most common and most rapidly increasing form of cancer in the United States. In fact, there
are now more cases of skin cancer in the United States than all other cancers combined In
1989, Ae Academy proclaimed skin cancer to be an "undeclared epidemic," a phrase that has
since been adopted by the Centers for Disease Control and Prevention (CDC). Half of all
cancer diagnoses are for skin cancer, and one American in six will develop skin cancer in his
or her lifetime. This year, nearly 1.2 million Americans will be diagnosed with non-
melanoma skin cancer. According to a recent survey of dermatologists, an additional 80,000
Americans m^ be diagnosed with mahgnant melanoma Altiiough highly curable if detected
and treated early, nearly 10,000 Americans will die of skin cancer this year ~ about 7,500
from malignant melanoma and the rest from non-melanoma skin cancers.
Basal cell carcinoma is the most common form of non-melanoma skin cancer and is 95%
curable. Basal cell usually presents as a slow-growing, raised, translucent nodule that may
American Academy of Dermatology
The Honorable George E. Brown, Jr.
Sqjtember 18, 1995
Page 3
a pencil azsa. If you have any of these warning signs, the Academy urges you to visit your
dermatologist or personal physician, immediately.
With this background, let me try to address die specific issues dted in your letter.
"Is there compelling laboratory or observational evidence that UV-B
radiation is related to the incidence of skin cancer cases including
'Tfffaffl'ffW ffffrf non-melanoma cancers?"
The American Academy of Dermatology strongly believes that a decline in stratospheric
ozone will be injurious to human health. As you know, the stratospheric ozone layer
regulates the degree of ultra-violet (UV) irradiance on the earth's surface. Ozone is a
selective filter, blocking all ultra-violet C (UVC) radiation, some ultra-violet B (UVB)
radiation, and litde ultra-violet A (UVA) radiation.
Recendy, scientists at the World Meteorological Organization (WMO) reported that the
seasonal hole in the earth's ozone layer over Antarctica is growing faster dian ever and is
already twice the size that it was at this same time last year. The ozone is also deteriorating
over die northern hemisphere, but to a lesser extent. The WMO reports that ozone over
Europe and North America has diminished 10%-15% since 1957, and the ultra\iolet
radiation has increased 13%-15%.
Even small decreases in ozone levels may result in a significant increase in die amount of
UVB radiation at the earth's surface. Increased exposure to UVB radiation is deleterious to
human skiiL UVB radiation causes sunburn, the {^toaging of the skin and, since 1 894, has
been definitively hnked to the devdopment of non-mdanoma skin cancers. Decreases in the
integrity of our stratos{^eric ozone will significandy increase the incidence of sunburn,
accelerate the aging process, increase die incidence of non-melanoma skin cancers (as well
as decease the age of onset for these cancers), and impact other skin disease. Exposure to
UV radiation can initiate or aggravate certain serious diseases such as lupus erythematosus,
porphyrias, hopes simplex, and other infectious diseases. Exposure to the sun can adversely
affect individuals who are taking many medicadons, including over-the-counter drtigs like
ibuprofen and diuretics, and may impede certain vaccinations.
American Academy of Dermatology
The Honorable George E. Brown, Jr.
September 18, 1995
Page 2
crust, become ulcerated and possiUy bleed without treatment Individuals with light hair and
eye color and a fair complexion are considered to be at Ugh lisk for this form of skin cancer.
Basal cell carcinoma rarely metastasizes. It can, however, a£fect underiying structures,
causing considerable damage, disfiguronent, and disability. I have enclosed several explicit
photographs, highUghting the significant damage caused by basal cell carcinoma
Dermatologists consider these cancers to be a very serious condition.
Squamous cell carcinoma is anodier form of non-melanoma skin cancer and is also 95%
curable, if propoiy treated in its early stages. Typically, squamous cell carcinoma appears
as a raised, red or pink scaly nodule or wart-like growth on die face, hands, or ears.
Squamous cell carcinomas can grow in size, cluster, and spread to other parts of the body.
Squamous cell cardnoma is two to three times more common in men than in women. I have
also enclosed examples of squamous cell carcinomas to illustrate that diese non-melanoma
skin cancers are equally serious.
MaUgnant mdanoma is the most deadly form of skin cancer, and die eighdi most diagnosed
cancer in our nation. The incidence rate of maUgnant melanoma per 1 00,000 Americans is
increasing at the rate of 4.2% per year, faster than that of any other cancer. The mortality
rate for malignant melanoma is also increasing, but fortunately at a much slower rate.
Malignant mdanoma begins in the body's melanocytes, the skin cells that produce die dai^
protective jxgment called melanin. It is melanin that is responsible for suntanned skin, acting
as a partial protection against the sun's damaging rays. Melanoma may suddenly appear
without warning, but it may also begin in or near a mole or other dark spot in the skin.
Having dark brown or black skin is not a guarantee against melanoma Afiican Americans
can develop mdanoma, eq)ecially on die palms, soles, under finger and toenails, and in the
moudi. Malignant mdanoma is die leading cancer in young women in their twraities and is
second only to breast cancer for women in dieir thirties.
For years, the Academy has recommended diat every American examine his or her skin
fi-equentiy to look for die dangers signs of melanoma, also known as die ABCD's of
mdanoma "A" stands for asymmetry ~ one half of die lesion is unlike the other. "B" is
for border irregularity - a scaUoped or poorly circumscribed border. "C" stands for color
variabiUty — does the color of the lesion vary fixim area to area or has die lesion changed in
color. "D" is for diameter - lesions should be no larger than 6 millimeters, the diameter of
10
American Academy of Dermatology
The Honorable George E. Brown, Jr.
SqXember 18, 1995
Page 4
"Is there compelling evidence that a decrease in stratospheric ozone and the
consequent increase in UV-B will lead to an increase in the incidence of
skin cancer?
The Academy believes that there is sufiScient evidence that a decline in stratospheric ozone
will result in a higher incidence of skin cancer. For each 1 % depletion of ozone, the rate of
squamous cell carcinoma is expected to increase by 2%-5%, and the rate of basal cell
carcinoma by l%-3%. That same 1% decline in ozone integrity is expected to increase the
incidence of melanoma mortality by .8% to 1.5%. It has been reported that a 10% reduction
in stratospheric ozone could increase squamous cell carcinoma rates by 16%- 18%.
"Is there any basis for the claim that '...melanoma is mainly due to UV-A.
which is not absorbed by ozone. Therefore, melanoma rates should not Ik
qffected by changes in the ozone layer. '?"
While the action spectrum for melanoma is not complete, there is consensus among
dermatologists and phctobiologists that there is a linkage between malignant melanoma and
UVB radiation. Excessive exposure to the sun and childhood sunburns are accepted as a
cause of melanoma, especially among light-skinned people Dermatology does not accept
that UVA is solely responsible for the development of malignant melanoma
Of course, an increase in incidence will certainly be accompanied by a commensurate
increase in treatment and other costs associated with skin cancer. It is estimated that over
$1 biUion are spent annually in the United States for the treatment of malignant melanoma.
As mahgnant melanoma is highly underreported (most are treated on an outpatient basis and
hence are not reported to most cancer registries), this number may be well below the true
cost of treatment. Increases in incidence, especially incidence of more advanced cases of
malignant melanoma, would proportionately increase treatment costs.
Until the ozone layer repairs itself we can only hope to mediate these dire predictions by
taking action to stabilize the ozone and by making important changes in our sun habits and
dothing choices. The Academy is working with the CDC for new and better ways to educate
the population, especially children, about the dangers of sun exposure. Of course, the most
effective preventive method is sun avoidance, especially deliberate sunbathing. There is no
such thing as a safe tan. If you must be in the sun between the peak hours of 10:00 am and
11
American Academy of Dermatology
The Honorable George E. Brown, Jr.
September 18, 1995
Page 5
4:00 pm, the following i^ecautions are recommended wear a wide-brimmed hat, sunglasses
and protective, tightly-woven clothing as well as a broad spectrum sunscreen with a sun
protection fact (SPF) or at least 1 5. Sunscreens should be e^jplied twenty minutes prior to
going outdoors. Water-resistant sunscreens should be reapplied often, especially after
swimming or strenuous exercise. Remember, sun protection is also important during the
winter and on cloudy days.
In addition, the Academy believes that the newdy created UV Index will prove to be an
important tool in our efforts to educate Ae pubhc about the dangers of sun exposure. Similar
indexes have proven valuable in Austraha, New Zealand, and many other countries. The UV
Index is a joint program of the National Weather Service, the Environmental Protection
Agency, and the CDC. The UV Index measures the amount of solar radiation that reaches
the earth on a scale of 1-10. Public health education messages have been developed to
educate individuals about the importance of taking protective measures. Currently, the
National Weadier Services provides the UV Index in 58 cities. The Academy supports a fiill
national roll-out of this important program to the 160 cities currendy served by the National
Weather Service.
I hope that this information is helpful. If I or the Academy can be of fiirther assistance to
you and the conunittee, please do not hesitate to call on us again.
Sincerely
Rex A. Amonette, MD.
President
RAA/ch
Enclosures
12
Mr. Brown. And I thank the Chairman for his courtesy.
Mr. ROHRABACHER. Thank you very much. And I appreciate the
distinguished former chairman of the Science Committee being
with us today. He has a treasure house of experience and we ap-
preciate him sharing that with us today.
Now we have two members with us. If they would Hke to give
very short opening statement.
No? And Mr. Ehlers, would you like to give a short opening state-
ment?
Mr. Ehlers. Thank you, Mr. Chairman.
First, I also commend you for calling the hearing. I think this is
an issue that should be aired for a number of reasons which will
emerge during the hearing.
My comments that I will offer will be short and just from my per-
spective as a scientist, and also in the context of Congressman
Brown's statement. I will be offering them as a politician who
doesn't exaggerate.
So we hope they can shed a little light on this.
I think the key point to remember is that most of the issues we'll
be discussing today are what Alvin Weinberg, former director of
Oak Ridge, called trans-scientific issues. They are scientific in their
origin, but they're in a sense beyond science because we cannot do
the experiments. We cannot go up and create an ozone hole and see
what the impact is.
And so we can merely observe, model, predict. Then observe
again, model again, predict again.
This results in large uncertainties in the scientific results.
And the difficulty is that, as a result of that, you will find sci-
entists on both sides of issues and to compound the difficulty, advo-
cates of one position or another will tend to look only at the evi-
dence offered by the scientists who support their position and wave
that triumphantly and say that science proves that such and such
a policy is right or it proves it is wrong.
I think it is very important for us, those of us who are laymen
and those of us who are scientists, to be very careful in this area.
I think it's important to be objective. It's important to be holistic
and look at the entire picture and not latch onto just one particular
contaminant and say the world is going to end if we don't take care
of that, without recognizing the issues that are brought forward by
that action.
As Garrett Harden once observed, you can never do just one
thing to the environment. You do one thing, it has repercussions
in many ways.
So be objective. Be holistic. Be patient. It takes time to work out
the science in some of these issues. It may take a decade or two.
In the meantime, we have to be very careful in interpreting and
understanding the results.
And finally, be prudent. Act on the information you have, but
don't go overboard and set up a major policy which it turns out is
extremely difficult to change once the science is found to be more
firm, more definite, and requires a change in policy.
So my plea to everyone on all of these issues is to understand
the limitations of science, not trum.pet a particular result as ending
13
the debate simply because it supports your position and, above all,
be objective, be holistic, be patient and be prudent.
Thank you, Mr. Chairman.
Mr. ROHRABACHER. Mr. Ehlers, of course, is one of the few sci-
entists that we have here in Congress. We have a large number of
lawyers, but just a few scientists. His opinion is respected and
thank you very much for those words of wisdom.
Before we seat our first panel, we have two colleagues who have
drafted legislation affecting the CFC ban here with us for remarks.
One is Congressman Tom DeLay, who will be arriving momentar-
ily. He is the distinguished Majority Whip.
And my friend and colleague and fellow moderate from Califor-
nia, Congressman John Doolittle. Mr. DeLay will be here to speak
with us about H.R. 475, which would repeal provisions of the Clean
Air Act affecting the production of CFCs.
Mr. Doolittle has drafted legislation which would return the
phase-out of CFCs to the original schedule. That was before Sen-
ator Gore created the stampede.
And I would ask Mr. Doolittle to step forward now and if he
could be recognized for five minutes.
Mr. Doolittle?
STATEMENT OF THE HONORABLE JOHN T. DOOLITTLE, A REP-
RESENTATIVE IN CONGRESS FROM THE 4TH CONGRES-
SIONAL DISTRICT OF THE STATE OF CALIFORNIA
Mr. Doolittle. Mr. Chairman, and Members of the Subcommit-
tee, I appreciate your holding this hearing. I think it's vital that
we air these issues.
Mr. Chairman, I'm going to leave to the capable scientists that
will follow me today, and their testimony, discussion as to whether
sound science justifies any ban on the production of CFCs.
My own belief is that the question is still very much open to de-
bate.
I am convinced, however, that although further research may
possibly support a future phase-out of CFC production, to date,
there has not been a sufficient showing of scientific evidence to jus-
tify the current and rapidly approaching ban date of December 31,
1995.
That's why today I am introducing legislation that, if enacted,
would push the ban on CFC production back to the original date
set in the Clean Air Act amendments of 1990, which is January 1,
2000.
There are several reasons why I believe we should adopt this pol-
icy.
First, the so-called scientific findings that precipitated the accel-
eration were retracted by NASA, the agency that first announced
them.
Under the Clean Air Act, in the 1987 Montreal Protocol, CFCs
were to be phased out with a total ban in production taking effect
on January 1, 2000.
But in February of 1992, NASA scientists held an emergency
press conference to announce that an ozone hole similar to the ones
over Antarctica would soon open over the Arctic and parts of North
14
America. The story was widely reported as a looming environ-
mental catastrophe.
Time magazine showcased the impending disaster on the cover
of its February 17 issue.
Within days, the U.S. Senate voted 96 to zero to accelerate the
phase-out. President Bush agreed. According to author Ronald Bai-
ley, less than a month after its emergency press conference, "sat-
ellite data showed that the levels of ozone-destroying chlorine had
dropped significantly and provided absolutely no evidence of a de-
veloping ozone hole over the United States."
NASA waited until April to announce at another press conference
that a large Arctic ozone hole had been, quote/unquote, "averted."
Did NASA's admission allay the fear and panic whipped up by
the earlier prediction of apocalypse?
Clearly not. The retraction received far less attention than the
initial announcement. And in what must have been a very busy
news week. Time magazine buried NASA's admission in four lines
of text in its May 11 issue.
Thus, despite the fact that the primary threat used to justify ac-
celeration of the CFC ban never materialized, the accelerated
phase-out remains in place.
The second reason I support returning the ban to its original
date is because of the astronomical costs associated with the accel-
erated phase-out. There is a large amount of CFC-dependent refrig-
eration and air-conditioning equipment in use today. Higher CFC
costs and onerous EPA regulations have already resulted in sub-
stantially higher repair costs for these systems.
Ben Lieberman of the Competitive Enterprise Institute, whom I
believe you will hear from today, has estimated the cost of the ac-
celerated CFC ban, that that cost could reach as high as $100 bil-
lion. Some feel that this estimate is too conservative.
But, as it stands, this total represents $1,000 per-household tax.
Such an enormous drain on the nation's economy would have to
be considered, even in the face of a proven environmental catas-
trophe. Yet, as I have mentioned, and as others will testify, the
science behind the accelerated ban remains unsubstantiated.
The third reason to delay the ban is because the cost-benefit
analysis originally performed by the EPA to justify acceleration
was flawed. The EPA under-estimated the costs I just referred to,
and over-estimated the benefits.
Among the primary benefits, according to the EPA, was protec-
tion against melanoma skin cancer. A 1993 study, however, con-
cluded that this cancer is caused by longer wavelength ultraviolet
radiation, UVA, which is not screened by ozone, not by UVB, which
is.
In other words, a rise in the incidence of melanoma cases does
not depend on the level of ozone in the atmosphere.
Thus, the benefits EPA attributes to banning CFCs at the close
of this year have been grossly overstated.
Mr. Chairman, in closing, I want to touch upon one more point
that was raised in a Wall Street Journal article recently, entitled,
"Controversy Is Brewing Over the Effects of Chemicals That Are
Replacing CFCs."
15
An official from DuPont was asked about the possible harmful ef-
fects revealed by the study. The official dismissed the researcher's
conclusions, saying they were based on worst-case scenarios.
Mr. Chairman, the extreme environmental movement uses every-
thing based on worst-case scenarios. It's dismaying to see that Du-
Pont apparently is using that now.
From today's testimony, Mr. Chairman, you will discover that
worst-case scenarios have been driving this debate. Those of us
who are skeptical about the need for an accelerated ban note that
under the proponents' own worst-case scenario, the increased risk
of skin cancer — imagine this — the increased risk of skin cancer that
one would face without the ban is equivalent to moving 60 miles
closer to the equator, for instance, from Washington, D.C. to Rich-
mond, Virginia, or perhaps Beverly Hills down to where you surf
in Laguna — if that's where you surf. Some place in your district,
I'm sure — that Laguna isn't somebody else's.
Instead of responding with scientific facts, some NASA scientists,
EPA officials, and extreme environmental organizations have
forced this imminent CFC phase-out on the American people using
fear and doomsaying.
It was the EPA that predicted in 1987 that 3 million skin cancer
deaths would occur in the United States unless CFC production
were curtailed. And it was NASA that predicted in 1992 that an
ozone hole would open over much of the United States, Europe and
Russia.
I hope this Subcommittee today will look at all of the facts in-
volving the use of CFCs and their effect on the environment. I be-
lieve we should not allow the prohibition of CFCs to take place
until Congress weighs the true costs and benefits of the accelerated
ban.
Sound science must be the basis for all future decisions we make
on this important issue and I commend the Chairman and this
Subcommittee for using this forum to search for the truth.
[The complete prepared statement of Mr. Doolittle follows:]
16
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Testimony of
le Honorable John T. Doofetle
before
Energy and Environment Subcommittee
House Committee on Science
Septanber20, 1995
Mr Chainnan, Mwnbers of the subcommittee, thank you for allowing me this opportunity
to testify here today Td like to b^in by thanking the distinguished chairman for holding this
hearing on what I believe is a very important issue.
I would also commend to the Members of the subcommittee the insights of Dr. Singer of
The Science and Environmental Policy Project and Mr Ben Liebeiman of the Competitive
Enterprise Institute, both of whom have b^n very helpful in keeping me informed of the shaky
science and high costs associated with the impending ban on the production of
chlorofluorcarbons. I had not had the opportunity to meet Dr. Baliunis and Dr Setlow before
today, but I am familiar with their work in this area and am glad the subcommittee will get the
benefit of their testimony.
Mr. Chairman, I will leave to these capable scientists the discussion as to whether sound
science justifies any ban on the production of CFCs. My belief is that the question is still very
much open to debate. I am convinced, however, that although further research may possibly
support a fijture phaseout of CFC production, to date, there has not been a sufiBcient showing of
scientific evidence to justify the current and rapidly-approaching ban date of December 3 1
That's why today I am introducing legislation that, if enarted, would push the ban on CFC
production back to the original date set in the Clean Air Act Amendments of 1990 That original
date was January 1 , 2000. My bill requires that the EPA issue regulations allowing the
production of CFCs and halons listed as class I substances in accordance with section 604(a) of
the Clean Air Act In addition, my legislation would restore prior law in determining the base tax
amount for excise taxes on CFCs.
17
Mr. Chainnan, I would like to take a few minutes to explain why I do not believe we
should allow the CFC ban to take efiFect at the end of this year, rather than the original year 2000
date.
Rrrt, the so-called scientific findings that precipitated the acceleration were retiarted by
NASA, the agency that first announced them Under the Clean Air Act and the 1987 Montreal
Protocol, CFCs were to be phased out with a total ban on production taking effect on January 1,
2000 But in February 1992, NASA scientists held an "emergency" press conference to announce
that an ozone hole, similar to the ones over Antarctica, would soon open over the Arctic and parts
of North America. The story was widely reported as a looming environmental catastrophe Time
magazine showcased the impending disaster on the cover of its February 17 issue
Within days, the Senate voted 96 to 0 to accelerate the phaseout President Bush agreed
According to author Ronald Bailey, less than a month after rx& emergency press conference,
"satellite data showed that the levels of ozone-destroying chlorine... had dropped significantly and
provided absolutely no evidence of a devdoping ozone hole over the United States." NASA
waited until April to announce at another press conference that a large arctic ozone hole had been
"averted."
Did NASA's admission allay the fear and panic whipped up by the earlier prediction of
apocalypse? Not quite. The retraction received for less attention than the initial announcement.
And in what must have been a busy news week, rune magazine buried NASA's admission in four
lines of text in its May 1 1 issue.
Thus, despite the fact that the primary threat used to justify acceleration of the CFC ban
never materialized, the accelerated phaseout remains in place
Another reason I support returning the ban to its original date is because of the
astronomical costs associated with the accelerated phaseout. Thwe is a large amount of
CFC-dependent refrigeration and air-conditioning equipment in use today. Higher CFC cosU and
onerous EPA regulations have already resulted in substantially higher repair costs for these
systems One auto mechanic from Atlanta w*o was in Washington recently for the White House's
Small Business Conference said that he was embarrassed to hand his customers the bill after
recharging their cars' air-conditioners
Although I will defer to Ben Lirf)erman on the specifics of the cost estimates, I know that
he found the cost of the accelerated CFC ban could reach as high as $100 billion Some feel that
this estimate is too conservative, but as it stands, this total represents a $1,000 tax on every
household in America.
Such an enormous drain on the nation's econom> would have to be considered even in the
&ce of a proven environmental catastrophe. Yet, as I have mentioned and as others will testify,
the science behind the accelerated ban remains unsubstantiated
18
A third reason to delay the ban is because the cost-benefit analysis originally performed
by the EPA to justify acceleration was flawed. The EPA underestimated the costs I just referred
to and overestimated the benefits. Among the primary benefits, according to the EPA, was
protection against melanoma skin cancer. A 1993 study, however, concluded that this cancer is
caused by longer wavelength ultraviolet radiation (UVA) which is not screened by ozone, not by
UVB, which is. In other words, a rise in the incidence of melanoma cases does not depend on the
level of ozone. If this conclusion is true, the benefits EPA attributes to banning CFCs at the close
of this year have been greatly overstated.
Lastly, we have not allowed time for stable CFC replacements to develop. Again, I am
guessing that Ben Lid)erman will address this topic in more detail, but it is certainly worth
mentioning now. Before we replace CFCs, we had better make certain that we have workable
and safe replacements. It is not clear that we are there yet. Just a month ago, an article appeared
in the Wall Street Journal entitled "Controversy Is Brewing Over the Effects Of Chemicals That
Are Replacing CFCs." In explaining a study that concluded that CFC replacements may produce
a toxic byproduct, Tracey Tromp of the Atmospheric and Environmental Research Inc. said, "Our
concern is that we know abnost nothing about the alternatives [to CFCs]."
Mr. Chairman, in closing, I want to touch upon one more point that was raised in the
Journal article. An official fi-om DuPont was asked about the possible harmful effects revealed by
the study. The official dismissed the researchers' conclusions, saying they were based on
worst-case scenarios.
From today's testimony, Mr Chairman, you will discover that worst-case scenarios have
been driving this debate. Those of us who are skeptical about the need for an accelerated ban
note that, under the proponents' own worst-case scenario, the increased risk of skin cancer one
would face without the ban is equal to moving 60 miles closer to the equator, for instance, fi'om
Washington to Richmond. Instead of responding with scientific facts, some NASA scientists,
EPA officials, and extreme environmental organizations have forced this imminent CFC phaseout
on the American people with fear and doomsaying. It was the EPA that predicted in 1987 that 3
million skin cancer deaths would occur in the United States unless CFC production were
curtailed. And it was NASA that predicted in 1992 that an ozone hole would open over much of
the United States, Europe, and Russia.
I hope this subcommittee will look at all of the fiicts involving the use of CFCs and their
effect on the environment. I believe we should not allow the prohibition of CFCs to take place
until Congress weighs the true costs and benefits of the accelerated ban. Sound science must be
the basis for all future decisions we make on this important issue, and I commend the chairman
and this subcommittee for using this forum to search for the facts.
19
Mr. ROHRABACHER. Mr. Doolittle, thank you very much for your
legislation and your testimony today.
Ms. Rivers, do you have some questions that you'd like to ask?
Please proceed.
Ms. Rivers. ITiank you, Mr. Chair. And thank you. Representa-
tive Doolittle.
When I hear people say things like the evidence is not sufficient
at this time, it perks up my ears and it almost forces me to ask
the question, what would you consider to be sufficient evidence for
action to be taken in this area?
Mr. Doolittle. I think we need a clear scientific conclusion that
there is a definite cause for the problem and that so-called problem
is producing definite effects.
Theories or speculation about it are not sufTicient. We need
science, not pseudo-science. I think we've been in an era of pseudo-
science where these dire consequences are portrayed in order to
achieve a certain political objective.
Ms. Rivers. Are you a scientist?
Mr. Doolittle. I am not.
Ms. RiVers. You are not. Have you found in peer-review articles
or in the broader scientific discourse that people are saying, this
really is not a problem?
Mr. Doolittle. I have found that there is no established consen-
sus as to what actually the problem is. I found extremely mislead-
ing representations by the government and government officials
that are not founded on sound science.
Ms. Rivers. That's what I was asking about, is not government
scientists, necessarily, but peer-review articles, where scientists
who are out in academia who are doing this on a regular basis.
Could you give me an example of some of the peer-reviewed pub-
lications that you consulted in formulating your opinion that
there's no science?
Mr. Doolittle. Well, you're going to hear from one of the sci-
entists today. Dr. Singer.
Ms. Rivers. Dr. Singer doesn't publish in peer-reviewed docu-
ments.
Mr. Doolittle. You know, I'm not going to get involved in a
mumbo-jumbo of peer-review documents. There's politics within the
scientific community, where they're all intimidated to speak out
once someone has staked out a position.
Ms. Rivers. Right.
Mr. Doolittle. And thankfully, under this Congress, we're going
to get to the truth and not just the academic politics.
Ms. Rivers. And when I went to the University of Michigan, one
of the first things that I was taught about science is that you look
at the methodology of anyone who is making claims.
And the general way to feel certain that you're getting good
science is that you put your ideas out in a straightforward way in
a peer-reviewed publication and you allow others who are doing the
same work to make comments, to criticize, to replicate your find-
ings.
And what I'm asking you, in your search for good science, is what
peer-reviewed documentation did you use to come up with your de-
cision?
20
What good science did you use to rely on?
Mr. DOOLITTLE. And my response to you is it is the proponents
of the CFC ban that have the burden of producing the good science.
I do not have that burden.
They have failed to meet their burden and until and unless they
meet that burden, we should role back that date. I believe the
extra years that we provide may give that opportunity.
Ms. Rivers. Where I started this line of questioning was with
your statement that the reason you oppose this is that there's not
sufficient proof. I asked you what sufficient proof would be? You
told me good science. I asked you, did you actually consult any of
the sources that would be considered good science in scientific cir-
cles? And you said, no.
So I'm back to what are you
Mr. DOOLITTLE. I didn't say, no. I consulted Dr. Singer, who is
a very authoritative source, and I will stand with the doctor.
Ms. Rivers. Okay. Thank you.
Mr. ROHRABACHER. Of course, today, there are two questions.
Number one, we have to define the problem. And number two, we
have to say whether the solution that has been put forward, and
that is, banning CFCs and having a major speed-up of that ban,
whether or not that actually works and whether or not it is worth
the cost to the consumer and to the American people.
We'd now like to, with the permission of my colleagues, I'd like
to call on Mr. DeLay.
Thank you very much, Mr. Doolittle. I appreciate your comments
very much.
You've already been introduced, Mr. DeLay. Sometimes it's very
difficult for me when I'm talking about my colleagues and introduc-
ing them, and I almost introduced Mr. DeLay as the Minority
Whip.
It just feels so good to introduce you as the Majority Whip. Mr.
DeLay, if you would like to proceed. You've already been intro-
duced.
STATEMENT OF THE HONORABLE TOM DeLAY, A REPRESENT-
ATIVE IN CONGRESS FROM THE 22D DISTRICT OF TEXAS
Mr. DeLay. Well, thank you, Mr. Chairman, and I do apologize
for being late. The meeting with the Speaker ran a little longer
than we thought and it's hard to get up and leave for the Speaker.
But I do appreciate you allowing me the opportunity to partici-
pate in this very important debate on the phase-out of CFCs and
the depletion of the ozone layer.
Let me start, Mr. Chairman, by saying that I recognize the im-
portance of clean air and a healthy environment. There's been a lot
said about those of us that are asking for reasonableness and good
science when you make regulations and disrupt people's lives.
But dirty air and harmful ultraviolet rays affect me and my fam-
ily just as much as any other American.
I'm here today because I believe that the science underlying the
ban on CFCs and the connection between health and ozone deple-
tion is debatable.
We all know, or some of us know, that recent studies have shown
that as much as 95 percent of light-induced melanoma is caused by
21
visible spectrum of light, and not by the ultraviolet light that is fil-
tered by the ozone layer. Evidence of this nature justifies a com-
prehensive review of the impact of the CFC ban on our health and
on our economy, thereby on the lives of the American families.
As everyone at this hearing knows, the Clean Air Act Amend-
ments of 1990 require that CFCs, a widespread class of refrig-
erants used in air conditioners and refrigerators and billions of dol-
lars' worth of equipment, to be phased out of production out of fear
that CFCs leak into the atmosphere and deplete the earth's ozone
layer.
What is not so well known is that this ban is the result of a
media scare some years ago from individuals who have not backed
away from a number of their claims.
Most notably, on February the 3rd of 1992, just as an example
of the kind of scare, the NASA scientists called an emergency press
conference to announce that severe ozone depletion over the Arctic
and a large part of North America was imminent, which received
extensive media coverage and aroused much alarm amongst Ameri-
cans.
Just a few months later, and with much less fanfare, NASA
quietly admitted that its prediction was wrong. The retraction went
largely unnoticed and had no effect on law.
Scientific evidence has shown that natural resources dominate
the stratospheric chemicals that are suspected to cause ozone de-
pletion. This evidence indicates that the ozone hole is controlled by
climatic factors, rather than the amount of chemicals in the atmos-
phere.
Just this past July, the Washington Post reported that a team
of scientists from MIT had shown that the concentration of ozone-
depletion CFCs in the atmosphere is declining. While some sci-
entists would have us believe that the depletion of the ozone layer
is the result of decades of environmental negligence, they would
also have us believe that the current phase-out of CFCs, which has
been in place for less than a decade, is responsible for the remark-
ably swift reduction in the level of CFCs in the atmosphere.
I'm inclined to believe that we are not giving Mother Nature
nearly enough credit.
It's clear that man-made CFCs do not have as much of an effect
on the atmosphere as normal climatic fluctuations.
With CFC production in the United States scheduled to end by
the end of this year, owners of air conditioning and refrigerating
equipment are having to prematurely replace their equipment or
use substitutes, many of which are distinctly inferior.
In the rush to replace CFCs, it is obvious that little or no
thought has been given to the long-term effects of the new com-
pounds on our environment.
Recent studies indicate that some of the replacement compounds
significantly increase acid rain levels. In addition, the compounds
being produced to replace CFCs are unpredictable and in some
cases, dangerous. Some of the replacement compounds are highly
flammable and others have been plagued by sudden and unex-
pected explosions.
CFCs affect the lives of almost every American, however. Almost
no thought was given to how the CFC ban will affect the consum-
22
ers who bear the brunt of the costs. This phase-out may well be the
single most expensive environmental measure to date with an esti-
mated cost of $50 to $100 billion over the next decade — and every
red cent will come out of the pockets of the American family.
According to Ben Lieberman of the Competitive Enterprise Insti-
tute, the most immediate impact on consumers is the increased
cost of maintaining car and truck air conditioners. Americans own
140 million air-conditioned vehicles which use CFC-12 as their re-
frigerant, and the most common problem is the loss of refrigerant
through leaking.
Service stations are now charging $50 to $200 more than they
used to for this repair, since the law requires them to take addi-
tional steps to reduce the amount of refrigerant that escapes dur-
ing services.
Drivers that cannot afford to have their cars retrofitted with new
air conditioning equipment, at a cost of as much as $1,000, will
have to compete for dwindling supplies of CFCs at greater in-
creased costs. At the time the ban was implemented, CFCs cost in
the neighborhood of $1 a pound. Now they cost as much as $15 a
pound.
As might be expected, these skyrocketing prices have given rise
to a flourishing international CFC black market.
The phase-out will also affect the cost and quality of domestic re-
frigerators. Refrigerators using CFC substitutes will cost $50 to
$100 more, and probably need replacement three to five years soon-
er than their CFC-12 predecessors.
The absurdity is that refrigerators only use four to six ounces of
refrigerants each, so they are negligible contributors to atmospheric
CFC levels.
And finally, I would like to point out that very little consider-
ation has been given to the potential effect of this ban on energy
consumption in the United States. Evidence indicates that CFCs
are more energy-efficient than replacement compounds. This means
we will need more gasoline to operate our cars and trucks and
more electricity to support the needs of home and industrial refrig-
eration units.
If this is the definition of environmental progress, the need for
a comprehensive review of this ban is self-evident.
Is the cost worth it? I don't think so, especially when scientific
evidence linking CFCs to atmospheric damage is ambiguous.
While scientists offer the American public a dizzying array of
facts and opinions on the relative importance and status of the
ozone layer, billions of dollars are being spent to develop a new
technology that may not even be necessary.
Mr. Chairman, I commend you for holding these timely and im-
portant hearings. Congress needs to review this issue thoroughly,
and the American people need to understand the real dangers and
the real costs associated with banning CFCs.
Ultimately, we must make sure that we are not jumping out of
the frying pan and into the fire.
[The complete prepared statement of Mr. DeLay follows:]
23
STATEMENT OF THE HONORABLE TOM DeLAY
THE COMMITTEE ON SCIENCE
SUBCOMMITTEE ON ENERGY A^fD ENVIRONMENT
The Real Cost of the CFC Ban
September 20, 1995
Mr. Chairman, thank you for allowing me the opportunity to participate
in this very important debate on the phaseout of CFCs and the depletion of the
ozone layer.
Let me start by saying that I recognize the importance of clean air and a
healthy environment. Dirty air and harmful ultraviolet rays affect me and my
family just as much as every other American. I am here today because I
believe that the science underlying the ban on CFCs, and the connection
between health and ozone depletion is debatable.
Recent studies have shown that as much as 95 % of light-induced
melanoma is caused by the visible spectrum of light, and not by the ultraviolet
light that is filtered by the ozone layer. Evidence of this naoire justifies a
comprehensive review of the impact of the CFC ban on our health and on our
economy.
As everyone at this hearing knows, the Clean Air Act Amendments of
1990 require chlorofluorocarbons (CFCs), a widespread class of refrigerants
used in vehicle air conditioners, refrigerators, and billions of dollars worth of
equipment, to be phased out of production out of fear that CFCs leak into the
atmosphere and deplete the earth's ozone layer.
What is not so well known is that this ban is the result of a media scare
some years ago from individuals who have now backed away from a number
of their claims.
24
Most notably, on February 3, 1992, NASA scientists called an
"emergency" press conference to announce that severe ozone depletion over the
Arctic and a large part of North America was imminent, which received
extensive media coverage and aroused much alarm. A few months later, and
with much less fanfare, NASA quietly admitted that its prediction was wrong.
The retraction went largely unnoticed and had no effect on law.
Scientific evidence has shown that natural sources dominate the
stratospheric chemicals that are suspected to cause ozone depletion. This
evidence indicates that the ozone "hole" is controlled by climactic factors
rather than by the amount of chemicals in the stratosphere.
Just this past July, the Washington Post reported that a team of scientists
from MIT have shown that the concentration of ozone -depleting CFCs in the
atmosphere is declining. While some scientists would have us believe that the
depletion of the ozone layer is the result of decades of environmental
negligence, they would also have us believe that the current phaseout of CFCs,
which has been in place for less than a decade, is responsible for the
remarkably swift reduction in the level of CFCs in the atmosphere. I am
inclined to believe that we are not giving Mother Nature nearly enough credit-
-it is clear that man-made CFCs do not have as much of an effect on the
atmosphere as normal climactic fluctuations.
With CFC production in the United States scheduled to end by the end of
this year, owners of air conditioning and refrigeration equipment are having to
prematurely replace their equipment or use substitutes, many of which are
distinctly inferior.
25
In the rush to replace CFCs, it is obvious that little or no thought has
been given to the long-term effects of the new compounds on our environment.
Recent studies indicate that some of the replacement compounds significantly
increase acid rain levels. In addition, the compounds being produced to
replace CFCs are unpredictable and in many cases dangerous. Some of the
replacement compounds are highly flammable and others have been plagued by
sudden and unexpected explosions.
CFCs affect the lives of almost every American, however, almost no
thought was given to how the CFC ban will affect the consumers who to bear
the brunt of the costs. This phaseout may well be the single most expensive
environmental measure to date with an estimated cost of $50 to $100 billion
over the next decade-and every red cent will come out of the pockets of
American families.
According to Ben Lieberman of the Competitive Enterprise Institute, the
most immediate impact on consumers is the increased cost of maintaining car
or truck air conditioners. Americans own 140 million air.conditioned vehicles
which use CFC- 12 as their refrigerant, and the most common problem is a loss
of refrigerant through leaking. Service stations are charging $50 to $200 more
than they used to for this repair since the law requires them to take additional
steps to reduce the amount of refrigerant that escapes during servicing.
Drivers that cannot afford to have their cars retro-fitted with new air
conditioning equipment, at a cost of as much as $1000, will have to compete
for dwindling supplies of CFCs at greatly increased costs. At the time the ban
was implemented, CFCs cost in the neighborhood of $1 per pound. Now they
cost as much as $15 per pound. As might be expected, these skyrocketing
prices have given rise to a flourishing international CFC black-market.
26
The phaseout will also effect the cost and quality of domestic
refrigerators. Refrigerators using CFC substitutes will each cost $50 to $100
more and probably need replacement 3 to 5 years sooner than their CFC- 12
predecessors. The absurdity is that refrigerators only use about 4 to 6 ounces
of refrigerants each, so they are negligible contributors to atmospheric CFC
levels.
Finally, I would like to point out that very little consideration has been
given to the potential affect of this ban on energy consumption in the United
States. Evidence indicates that CFCs are more energy efficient that the
replacement compounds. This means we will need more gasoline to operate
our cars and trucks and more electricity to support the needs of home and
industrial refrigeration units. If this is the definition of environmental
progress, the need for a comprehensive review of this ban is self-evident.
Is the cost worth it? I don't think so, especially when scientific evidence
linking CFCs to atmospheric damage is ambiguous. While scientist offer the
American public a dizzying array of facts and opinions on. the relative
importance and status of the ozone layer, billions of dollars are being spent to
develop a new technology that may not even be necessary.
Mr. Chairman, I commend you for holding these timely and important
hearings. Congress needs to review this issue thoroughly, and the American
people need to understand the real dangers and the real costs associated with
banning CFCs. Ultimately, we must make sure that we are not jumping out of
the frying pan, and into the fire.
27
Mr. ROHRABACHER. Thank you very much, Mr. DeLay. The legis-
lation that you have offered will come to grips with many of the
problems that yoU brought up today.
Before I ask some of our colleagues to comment, you're basically
saying that this ban, the environmental impact of what we have to
do because of the ban, could be worse than the problem itself.
Is that right?
When you say that the energy requirements on the alternatives
are increasing, and would increase the necessity of using more fuel,
what you are actually saying, then, is more carbo — they're not car-
bohydrates.
Carbohydrates is what you eat.
Mr. DeLay. Hydrocarbons.
Mr. ROHRABACHER. Hydrocarbons are going into the atmosphere.
Mr. DeLay. Well, certainly. I'll tell you, Mr. Chairman, and I
said it during the debate of the Clean Air Act of 1990. Hardly any-
one was listening, about 35 members were. And warned about
some of the things that were being done with very little scientific
basis to it.
In fact, in the case of the acid rain section of the Clean Air Act,
the NAPAP study was totally ignored.
This is a perfect example of why we desperately need some sort
of risk assessment, cost-benefit analysis in the promulgating of
these regulations.
Mr. ROHRABACHER. And some of the other problems you men-
tioned, besides the fluorhydrocarbons, the idea that there might be
some kind of acid rain.
And actually, I've read somewhere where there might be some in-
creased cause or risk of cancer by some of the alternatives to CFCs.
Is that correct?
Mr. DeLay. Well, I think you're going to have some panels of sci-
entists that probably speak to that better than I will. But I think
it's pretty clear, or at least there is another school of thought that
is not tied to Chicken Little approaches to the environment, that
suggest that particularly the CFCs are not doing the damage to the
ozone layer that has been claimed.
Mr. ROHRABACHER. So, just in summary, the ozone may not be
threatened as we are being told, and even making the matter
worse, some of the solutions for this problem that may or may not
exist, actually may cause more damage to the environment. And
that's what you're worried about.
Mr. DeLay. And that's what I'm worried about.
Mr. ROHRABACHER. Thank you very much. Do some of my col-
leagues— I guess Mr. Roemer or Ms. McCarthy?
Mr. Roemer, would you like to ask a question?
Mr. Roemer. Mr. Chairman, certainly Mr. DeLay has advocated
cost-benefit analysis, and that's something that our Committee has
worked very, very hard on.
I'm a strong supporter of the cost-benefit analysis and pushed
that when we were in the majority as the Democratic Party and
have worked in bipartisan ways with the new majority to get that
through this Committee and to get it on the floor. And I'm hopeful
that we can come up with a bill.
28
You mentioned that you'd like to see more peer review and cost-
benefit analysis in this particular area. I guess I would just ask for
your comments on the "Scientific Assessment Of Ozone Depletion:
1994".
In the back of it, starting on page 29 and going through page 36,
are seven pages of scientists that have contributed to this study as
peer reviewers.
I know that you are a strong advocate of NASA, as I am, al-
though we disagree on the space station. There are a host of dif-
ferent scientists from NASA Langley and Goddard and a host of
different space centers.
Don't you think that this is something, after seven pages of peer
reviewers, that that's something that you and I are trying to get
in terms of scientific basis for these kinds of studies, although you
might disagree with what the result is?
Mr. DeLay. I do agree. The problem is, as has been happening,
frankly, in the environmental movement for years, and as was out-
lined in an excellent book called "Toxic Terror" by Dr. Elizabeth
Wayland, who is president of the American Society of Health and
Safety, I think is the name of the organization.
The problem has been, is that, and it's my experience as a sci-
entist— my education is in biology and biochemistry — is that you
look at everybody and everything and consider all approaches to
developing, during the scientific method, to developing a conclu-
sion. And you don't weight it to one way or another. You want to
gain all the information you can and make a decision based upon
all the information.
And I haven't seen this study, so I can't comment on this particu-
lar study. But it's been my experience that a selective group, in
fact, is usually taken — well, let me put it a different way.
The conclusion is usually written before the study is even done,
in many cases. And we can show you time and time again where
that is the case.
In fact, politics has entered into it and you can look at the his-
tory of the NAPAP study, where the Executive Director came under
criticism and indeed was fired when the study was going contrary
to what some people wanted the conclusion to be.
So I think, because you're having this hearing, because people
from different points of view are being heard, then Congress can
make an intelligent decision.
Mr. ROEMER. I would just say that in looking through the dif-
ferent scientists listed over these seven pages, from NASA and
Harvard and Maryland and international institutes of science and
MIT, New Zealand, Germany, France, Japan, Russia, that the poli-
tics would be so different, that there probably is not some kind of
consensus that they reach beforehand.
But I would be interested in your comments.
Mr. DeLay. I can give you a list of scientists, too, Mr. Roemer.
I can give you scientists at the National Research Council. I can
give you scientists at the Lawrence Livermore National Lab. I can
give you scientists from Norway.
Mr. Roemer. They're in here. They're in here. Livermore is in
here as well, too.
29
Before I ask another question, let me yield to the gentlelady from
Michigan.
Ms. Rivers. Thank you, Mr. Roemer.
Mr. DeLay, one of the things that you just said struck me. You
said that one of the problems out there in science today is that peo-
ple don't want to look at both sides of the thing. They have a deci-
sion of what they want already. And then you proceeded to say
that you never looked at the most important study on this issue,
the most broadest, the one that has world-wide input.
Why did you not consult the assessment on ozone depletion when
you put together your proposal and built your position?
Mr. DeLay. Well, I just haven't been presented with the study
of late. I'll be glad to read it and give you my assessment of it.
Ms. Rivers. Thank you.
Mr. Roemer. I'd just say — is that my time, Mr. Chairman? I
don't have time for any other questions?
Mr. Rohrabacher. One more question.
Mr. Roemer. And it's more of a statement than a question, and
if you want to comment on it, Mr. Delay, I'd be happy to hear your
comments.
Certainly, there are different assessments and results in this
than what you've said today. The industry-led results and scientific
basis that worked closely with President Bush called for the policy
that has been developed over the last few years.
Your assessment today has been largely based upon a think tank
and their assessment, rather than the industry-based.
Mr. DeLay. That's not true. My assessment is from reading peo-
ple like Fred Singer, who I think is testifying before this Commit-
tee, reading Amie Goldback from Norway, reading others.
We also have a problem here, too. We're creating an environ-
mental industry that now, in fact, I've even heard from some peo-
ple that have spent a lot of money complying with the CFC ban,
and now they're very resistant to looking at lifting that ban be-
cause they've already spent a lot of money in compliance with gov-
ernment regulations.
Mr. Roemer. I just think we're going to have many interesting
opinions from the panels today and it would be helpful for you to
read this study and to listen to the various opinions being offered
today.
And then we'd love to have you testify again to our Committee
based upon that broad-based analysis.
Thank you, Mr. Chairman.
Mr. Rohrabacher. Thank you, Mr. Roemer. In fact, that's a per-
fect segue into — with no objection, the Chair will request that we
move forward with the scientists, rather than making this a discus-
sion between various elected officials on this issue.
We have distinguished scientists with us today. In fact, the Chair
has gone out of the way to make sure that both sides are equally
represented by prestigious individuals in the scientific community,
so that we can have a dialogue on the issue with the experts, rath-
er than between ourselves.
I'd like to thank Mr. DeLay very much.
Mr. DeLay. Thank you, Mr. Chairman.
30
Mr. ROHRABACHER. You have a piece of legislation that deals
with this issue. Mr. Doolittle has a piece of legislation that deals
with it as well.
We thank you very much for your testimony.
Mr. DeLay. Thank you, Mr. Chairman.
Mr. ROHRABACHER. And the panel will be seated. Panel No. 1
will be seated.
I'll tell you what I will do. I will make the introductions as they
are seated.
Now with us, Dr. Robert T. Watson, who is the associate director
of environment for the White House Office of Science and Tech-
nology Policy, and is a former director of NASA's Stratospheric
Ozone Program.
We also have with us, Dr. S. Fred Singer, who is professor emeri-
tus of environmental science at the University of Virginia, and is
founder and president of the Science and Environmental Policy
Project in Fairfax, Virginia.
Also with us is Dr. Daniel Albritton, and he is director of NOAA's
laboratory in Boulder, Colorado, and cochairs the United Nation's
Ozone Science Assessment Panel.
We have with us as well, Sallie Baliunas. She is a research astro-
physicist at the nonpartisan George C. Marshall Institute and
chairs their science advisory board.
We have with us, Professor Margaret Kripke, who chairs the de-
partment of immunology at the M.D. Anderson Cancer Center in
Houston, Texas.
And Dr. Richard Setlow, who is associate director of life sciences
at Brookhaven National Laboratory.
Before you start, let me tell you the ground rules.
Your complete testimony will be in the record. Without objection,
we will make their complete testimony a part of the record.
But I will ask each of you to summarize with five minutes. And
if you can summarize in five minutes, you will have much longer
to speak afterwards because what I'm hoping to do is to promote
a dialogue between members of the panel, as well as Members of
this Committee.
So if you could summarize to five minutes, it will be very helpful
to the Committee because it will help promote the dialogue. And
if you can go to your central points, I think that we can get to the
important issues and the areas of contention, of honest disagree-
ment, which is why we're here today.
So, with that, I think, Dr. Watson, we will begin with you.
STATEMENT OF DR. ROBERT T. WATSON, ASSOCIATE DIREC-
TOR OF ENVIRONMENT, OFFICE OF SCIENCE AND TECH-
NOLOGY POLICY, EXECUTIVE OFFICE OF THE PRESIDENT,
WASHINGTON, DC
Dr. Watson. Thank you, Mr. Chairman.
My name is Robert Watson. I'm the associate director of environ-
ment in OSTP. I co-chair the International Ozone Assessment
Panel, the former director of NASA's Stratospheric Ozone Program,
and have published extensively in the peer-reviewed literature on
key chemical processes occurring in the atmosphere.
31
I greatly appreciate being given the opportunity to present the
latest scientific findings of the international community to you and
your Subcommittee.
It's a pleasure to be able to address what I believe to be a real
success story — credible science combined with technological ad-
vances that have led to informed policy formulation at the national
and international level.
The scientific community, industry, environmental organizations,
and governments have all worked towards a common goal — the
cost-efiective protection of human health and our vital ecological
systems.
The American public can be proud that the U.S. provided sci-
entific and policy leadership, and partisan politics were put aside
to protect the health of Americans.
My testimony represents the views of the very, very large major-
ity of the international scientific community from academia, indus-
try, government labs, and environmental organizations, not the
views of single individuals with few, if any, relevant publication in
the peer-reviewed journals.
Hundreds of scientists from developed and developing countries,
some of whom at one time were skeptics, have been involved in the
preparation and peer-review of each of these assessments.
I believe it's particularly important to note that industry sci-
entists and industry-sponsored research played a vital role in these
assessments.
The key issues are very simple. The ozone layer limits the
amount of UV-B radiation reaching the earth's surface. Thus, a de-
crease in ozone will lead to an increase in UV-B radiation reaching
the earth's surface. Increased levels of UV-B reaching the earth's
surface will, not may, have adverse consequences for human
health, ecological systems, and air quality.
There is absolutely no doubt that the major sources of atmos-
pheric chlorine are from human activities, not from natural
sources. Human activity is also a major source of atmospheric bro-
mine.
Photochemically-active halogen species can catalytically destroy
stratospheric ozone. Each chlorine molecule can destroy tens of
thousands of ozone molecules and bromine is at least 50 times
more efficient.
Since the late 1970s, ground-based, balloon and satellite data
have documented significant decreases in column content of ozone
over Antarctica, about 60 percent, as shown in one of my figures
in my testimony, and drastic changes in the vertical distribution,
close to 100 percent loss of ozone at certain altitudes.
The Antarctic ozone holes in 1990, 1992, 1993, and 1994, were
the most severe on record.
As we speak today, and as expected, satellite, balloon, and
ground-based data show that the Antarctic ozone hole is once again
developing in the fashion similar to the last few years.
There is absolutely no doubt that the springtime Antarctic ozone
hole is due to the increasing concentrations of anthropogenic chlo-
rine and bromine. This conclusion is based on combining extensive
ground, aircraft, balloon and satellite data with laboratory data
and theoretical modeling.
32
The speculative and totally unsubstantiated hypothesis of Dr.
Singer presented before Congress a few weeks ago is totally incon-
sistent with the observational data and theory.
With respect to global ozone, the observational data, as I've
shown in figure 4 of my testimony, provides conclusive evidence
that ozone depletion is occurring at all latitudes, except the tropics,
and in all seasons.
Analysis of extensive ground-based Dobson and TOMS data
through 1994 has shown that column ozone has decreased by 5 to
6 percent in summer in the northern hemisphere, 9 to 11 percent
in winter/spring in the northern hemisphere, 8 to 9 percent in
southern mid-latitudes on a year-round basis.
Figure 5 in my testimony also shows the seasonal and latitudinal
trends, illustrating the very significant trends at middle and high
latitudes.
In each case, the natural periodic and episodic fluctuations are
taken into account — solar cycle, season and volcanic activities.
The weight of scientific evidence strongly suggests that the ob-
served mid-latitude ozone trends are due in large part to anthropo-
genic chlorine and bromine.
Ozone depletion is expected to peak within the next year or so,
reaching about 6 to 7 percent ozone depletion in northern mid-lati-
tude in summer and fall over the USA, and 12 to 13 percent in
winter over northern mid-latitudes, and about 11 percent in south-
ern mid-latitudes.
The projected changes in column ozone would be accompanied by
15 percent, 8 percent, and 13 percent increases in surface
erythemal radiation in winter/spring in the northern mid-latitudes,
summer/fall at northern mid-latitudes, and in the southern hemi-
sphere year-round.
The link between a decrease in stratospheric ozone and an in-
crease in surface UV has been further strengthened in recent
years. Measurements in Antarctica, Australia, Canada and Europe
have shown under clear-sky conditions when column ozone de-
creases, the amount of UV-B increases, exactly as expected by the-
ory.
DeLuisi of NOAA has recently concluded that the signal in the
Robertson Bergometer that so many people talk about is so noisy
due to day-to-day changes in UV-B, and calibration of the monitors
was so flawed, that no reliable data and trends can be derived.
Recent data suggests from the TOMS instrument that it is an ob-
served increase in ultraviolet radiation in early summer, spring
and late autumn at latitudes polar to 40 degrees north.
Of particular importance for human health are the increases in
the incidence of non-melanoma skin cancer, melanoma skin cancer,
eye cataracts, and a possible suppression of the immune-response
system.
Some, such as Fred Singer and Sallie Baliunas, try irresponsibly
to trivialize the issue of ozone depletion by noting that an ozone de-
pletion of the magnitude observed is equivalent to only moving
south by 100 miles or so.
The reason this risk is even this low is the success of the Mon-
treal Protocol and its Amendments and adjustments.
33
Without these international agreements, we would be facing fu-
ture increases in UV-B radiation of possibly 40 to 50 percent by
the middle or the end of the next century, and the comparable dis-
tance to move would be more like 1,000 miles or so.
There's a large difference in skin cancer rates between cities in
the northern half of the U.S. and those in the southern half. The
difference for white, Anglo-Saxon males in Albuquerque and Se-
attle is at least a factor of five difference.
In conclusion, the Montreal Protocol and its amendments and ad-
justments are a success story that will in the future save thou-
sands of American lives each year. Who amongst us would want to
turn back the clock by weakening the Montreal program, leading
to the deaths of innocent Americans for the sake of a few dollars?
[The complete prepared statement of Dr. Watson follows:]
34
Statement of
Dr. Robert T. Wategu
Assbciate DirecJoi-ef'Environinent
Office oTScIence and Technology Policy
Executive Office of the President
before the
Subcommittee on Energy and the Environment
Committee on Science
United States House of Representatives
September 20, 1995
Mr. Chairman and Members of the Subcommittee:
My name is Robert T. Watson, I am Associate Director of Environment in the Office of
Science and Technology Policy, a co-chair of the International Ozone Assessment Science
Panel, and the former Director of NASA's Stratospheric Ozone Program. I greatly appreciate
being given the opportunity to present the latest scientific findings of the international
community to you and your subcommittee. It is a pleasure to be able to address what I
believe to be a real success story: credible science, combined with technological advances dtat
lead to informed policy formulation at the national and international level. The scientific
community, industry, environmental organizations and governments all worked towards a
common goal: the cost-effective protection of human health and our vital ecological systems.
The American public can be proud that the U.S. provided scientific and policy leadership, and
partisan politics were put aside to protect the health of Americans.
My testimony represents ^e views of the very very large majority of the international
scientific community from academia, government laboratories, environmental organizations
and industry, not the views of single individuals with few, if any, relevant publications in
peer-reviewed journals. Hundreds of scientists, from developed and developing countries,
some of \^diom were at one time skeptics, have been involved in the preparation and peer-
review of each of a series of international scientific assessments conducted under the auspices
of the World Meteorological Organization and the United Nations Environment Programme.
Assessments have been issued in 1981, 1983, 1989, 1991, and the latest in 1994. I believe it
is particularly important to note that industry scientists and industry sponsored scientists (e.g.,
research sponsored by the Chemical Manufacturers Association Fluorocarbon Program Panel)
have played a vital role in each of the assessments.
In 1994, three state-of-the-art assessments were conducted in response to the mandate of the
Vienna Convention for the Protection of the Ozone Layer and its Montreal Protocol on
Substances that Deplete the Ozone Layer. These assessments included: (i) an assessment of
our understanding of the processes controlling the present distribution and rate of change of
atmospheric ozone; (ii) an assessment of the environmental impacts of ozone depletion; and
(iii) an assessment of the technological feasibility and economic costs associated with the
1
35
substitution of substances controlled under the Montreal Protocol. The scientific assessment
was co-chaired by Dr. Daniel Albritton of NOAA and myself; the impacts assessment was co-
chaired by Dr Jan van der Lean of the Netherlands and Dr. Manfred Tevini of Germany; and
the technology/economics assessment was chaired by Dr. Stephen Anderson of U.S. EPA.
The need for sound science and risk assessment as the basis for regulatory policy is absolutely
critical in this and other environmental issues. I believe that the scientific basis for decision-
making in the ozone issue is excellent, far better than for most other environmental issues.
This is largely because of the long-term commitment to a sound scientific research program
by both Congress, and by this and previous Administrations. The research programs from
NASA, NOAA, NSF, EPA, DOE and others provide much of the basic foundation for these
assessments.
My testimony will provide answers to what I believe are a number of the key science issues
of policy relevance: (i) Why do we care about the ozone layer?; (ii) What controls the amount
of ozone in the atmosphere?; (iii) Is there any evidence that human activities are changing the
atmospheric concentration of ozone?; (iv) What is tiie effect of the Montreal Protocol?; (v) Is
there any evidence of increased levels of UV-B radiation?; and (vi) What are the human
health impacts of ozone depletion?
Why do we care about the ozone layer?
o The Eardi's ozone layer limits the amount of harmful ultraviolet-B (UV-B) radiation (280-
320 nm) reaching the Earth's surface. Thus a decrease in ozone will lead to an increase in
UV-B radiation reaching the Earths surface.
o Increased levels of ultraviolet radiation (UV-B) reaching the Eardi's surface, will, not may,
have adverse consequences for human health, ecological systems and air quality. Of
particular importance for human health are increases in the incidence of non-melanonia
skin cancer (between half and one percent of all cases are fatal), melanoma skin cancer
(with a very high fatality rate), eye cataracts, and a possible suppression of the immune-
response system.
What controls the amount of ozone in the atmosphere?
o The abundance of stratospheric ozone is controlled by the balance between die production
of ozone and the loss of ozone. Ozone production is controlled by the rate of photolysis
of molecular oxygen, where-as ozone loss is governed by a series of complex chemical
reactions involving oxygen-, hydrogen-, nitrogen-, chlorine- and bromine-containing
species. The large majority of these chemical reactions are well understood over the
complete range of stratospheric temperature and pressure conditions.
36
Ozone depletion occurs when the rate of loss of ozone increases because of human
activities. This is predicted, and has been observed to occur, when human activities
increase the atmospheric concentrations of chlorine and bromine species.
There is no doubt that the major sources of atmospheric chlorine are from human
activities (e.g., chlorofluorocarbons, carbon tetrachloride, and methylchloroform), not from
natural sources such as methyl chloride, volcanoes or sea spray. Natural sources of
chlorine account for only 0.6 ppbv: less than 20% of total chlorine loading. The
atmospheric concentrations of HCl and HF have been observed to increase over the past
few decades: totally consistent with the major source of atmospheric chlorine being
anthropogenic halocarbons. Human activities are also a major source of atmospheric
bromine (methyl bromide and halons).
Long-lived chlorine- (e.g., chlorofluorocarbons and carbon tetrachloride) and bromine-
(halons) containing chemicals have no significant removal processes in the lower
atmosphere. Consequently, weadier patterns distribute them uniformly over the whole
globe and transport diem up into the stratosphere where the bulk of the Earth's protective
ozone layer resides.
Shorter-lived chemicals such as methylchloroform (a source of chlorine) and methyl
bromide (a source of bromine) do have chemical removal processes in the lower
atmosphere. Hence only a fraction of these chemicals emitted into Ae atmosphere reach
the ozone layer. Even these chemicals are relatively well mixed throughout the globe,
with slightly higher concentrations in the northern hemisphere where most of the
emissions occur.
These long- and shorter-lived organic halocarbons are broken down by photochemical
processes in the stratosphere into what are called "reservoir and photochemically active"
inorganic species. The photochemically active species (atoms and radicals) then
catalytically destroy stratospheric ozone dirough a series of chemical processes. These
chemicals are very efficient in destroying ozone: each chlorine molecule can destroy tens
of thousands of ozone molecules, and bromine is even more efficient in destroying ozone.
In fact bromine is at least SO times more efficient than chlorine in destroying ozone than
chlorine per molecule.
Antarctica is a very special situation. Chlorine and bromine are much more efficient in
destroying ozone over Antarctica than over mid-latitudes because of the unique
meteorological conditions in the stratosphere. These unique meteorological conditions
produce veiy cold temperatures which causes water vapor to condense into ice crystals.
These ice crystals transform most of the chlorine in the stratosphere from reservoir species
into "photochemically active" forms that can destroy ozone in the presence of sunlight.
Hence, almost all of the chlorine is available to destroy ozone over Antarctica.
37
Is there any evidence that human activities are changing the atmospheric concentration
of ozone?
o Observational data shows that ozone is being depleted in Antarctica and at mid- and high-
latitudes in both hemispheres. The magnitude of the ozone depletion over Antarctica is so
large that a statistical analysis of the data is not needed: greater than 60% in column
content and close to 100% loss at certain altitudes. In contrast, the magnitude of ozone
depletion at middle and high latitudes is smaller, such that statistical procedures are
required for an accurate determination of the trend. However, it is quite clear from the
work of statisticians from universities, government laboratories and industry that global
ozone depletion is occurring at a very significant rate.
Polar Ozone:
o Since the late-1970's ground-based, balloon and satellite data have documented significant
decreases in the total column content (Figure 1) ~ and even more drastic changes in the
vertical distribution (Figure 2) ~ of ozone over Antarctica every spring-time. The
Antarctic "ozone holes" of 1992, 1993 and 1994 were the most severe on record (deepest
and greatest areal extent), extending over the v\^ole Antarctic continent: an air mass close
to the size of North America. In each of these years, ozone was locally depleted by more
than 99% between 14 and 19 km.
o As we speak today, satellite, balloon and ground-based data show that the Antarctic ozone
hole is once again developing in a fashion similar to the last few years.
o There is no doubt that the spring-time Antarctic ozone hole is due to die increasing
concentrations of anthropogenic chlorine and bromine, not caused by methane and carbon
dioxide as suggested by F. Singer in his recent speculative and unsubstantiated
Congressional testimony of August 1, 1995 (before the House Commerce Committee,
Subcommittee on Oversight and Investigations). The consensus that chlorine and bromine
are responsible for the ozone hole is a conclusion based on combining extensive ground,
aircraft, balloon and satellite data, with laboratory data and theoretical modeling. Figure
3 shows the strong anti-correlation between the abundances of ozone and chlorine
monoxide, the key ozone-destroying species, i.e., as the abundance of chlorine monoxide
increases the concentration of ozone decreases.
o A substantial Antarctic ozone "hole" is expected to occur each spring for many more
decades because stratospheric chlorine and bromine abundances will approach the pre-
Antarctic-ozone-"hole" levels (late- 1970s) very slowly during the next century.
o In the late-winter/early-spring periods of 1991/1992 and 1992/1993, chemical losses of
ozone up to IS- 20% at some altitudes have been deduced from a series of intense
observations in the Arctic. These observations, coupled with model calculations, increase
38
our confidence in the role of chlorine and bromine in the observed ozone destruction. The
year-year variability in the photochemical and dynamical conditions of the Arctic limits
the ability to predict ozone changes in future years.
Global Ozone:
o The observational data provides conclusive evidence that ozone depletion is occurring at
all latitudes, except the tropics, during all seasons. Analysis of extensive ground-based
Dobson data and TOMS and SBUV satellite data through 1994 has shown ozone has
decreased by about S-6% in summer and 9-11% in winter/spring in northern mid-latitudes,
and by 8-9% at southern mid-latitudes on a year-round basis. At northern mid-ladtudes,
the downward trend in ozone between 1981 - 1991 was about 2% per decade greater
compared to that of the period 1970 • 1980. Natural periodic and episodic fluctuations are
taken into account (solar cycle, seasonal, volcanic, etc.). Figure 4 shows die observed
global ozone trends from 1979 to 1994, after allowing for the effects of solar variability,
die quasi-biennial oscillation (QBO) and seasonal cycles. Figure 5 shows the observed
ozone trends by season and latitude, illustrating significant trends at middle and high
latitudes.
- Periodic fluctuations in ozone caused by changes in the 1 1 -year solar cycle can be
removed from the record relatively well. The magnitude of solar cycle-induced
changes in ozone have been estimated from ground-based Dobson data (30-40 year
record) and the TOMS satellite data (IS year record). The best estimate probably
comes from the Dobson network, where Reinsel et al. concluded that the maximum to
minimum variation was 1.18±0.66%. Combining all data suggests that the peak-peak
magnitude of the solar cycle effect is between 1 and 2%, significantlv less than the
derived human-induced trend.
- The magnitude of the seasonal cycle, depends on geographic location, and while much
larger than the human-induced trend, is easy to remove quite accurately from the
record because of the large number of repetitive cycles.
• Random fluctuations, e.g., daily-weekly fluctuations caused by changes in
"meteorological" conditions in the troposphere and stratosphere, cannot be removed,
but are taken into account in the trend analysis using autocorrelation techniques.
- Episodic fluctuations, caused by volcanic eruptions, cannot, a priori, be easily removed
as the magnitude of the effect varies from one eruption to another. However, the
effect of a volcanic eruption lasts for only a few years, hence cannot be the cause of
any observed long-term trend.
o The weight of scientific evidence strongly suggests that the observed mid-latitude
downward trends of ozone are due in large part to anthropogenic chlorine and bromine.
This conclusion is based on combining ground, aircraft, balloon and satellite data, with
laboratoiy data and theoretical modeling. Figure 6 shows how well a theoretical model
simulates the diurnal cycle of the abundances of key atmospheric constituents.
3d
What is the effect of the Montreal Protocol?
The rate of increase of atmospheric chlorine and bromine has slowed considerably in
recent years demonstrating the effectiveness of the Montreal Protocol and its amendments.
Even so, the mid-latitude ozone loss and the hole over Antarctica are not expected to
disappear until the middle of the next century because of the very long atmospheric
residence times for the CFCs and halons, i.e., human emissions between 1960 and today
will affect the health of future generations.
Human-induced ozone layer depletion is expected to peak around the year 1998, since the
peak stratospheric chlorine and bromine abundances are expected to occur then. Based on
extrapolation of current trends, observations suggest that the maximum ozone loss, relative
to the late 1960s, will likely be:
(i) about 12 - 13% at Northern mid-latitudes in winter/spring;
(ii) about 6 - 7% at Northern mid-latitudes in summer/fall; and
(iii) about 11% (with less certainty) at Southern mid-latitudes on a year-roimd basis.
These projected changes in column ozone would be accompanied by 15%, 8%, and
1 3% increases, respectively, in surface erythemal radiation, if other influences such as
clouds remain constant.
Without the Montreal protocol and its amendments and adjustments future levels of
atmospheric chlorine and bromine would be far higher than today (Figure 7). Hence,
future levels of ozone depletion, ground-level UV-B, and cases of skin cancer would be
substantially higher than today. Figure 7 shows how the Copenhagen amendments limit
peak stratospheric chlorine loading to about 3.S ppbv, decreasing to about 2 ppbv by about
2050, at ^^4lich time mid-latitude ozone depletion and the Antarctic ozone hole should
have recovered. Even with the Montreal Protocol, stratospheric chlorine levels were
projected to continually increase, exceeding 10 ppbv in the latter part of the century.
Is there any evidence of increased levels of UV-B radiation?
o The link between a decrease in stratospheric ozone and an increase in surface ultraviolet
(UV) radiation has been further strengthened in recent years. Measurements in Antarctica,
Australia, Canada and Europe have shown that under clear sky conditions when column
ozone decreases the amount of UV-B radiation increases by the amount expected from
theory (Figure 8). Large increases of surface UV are observed in Antarctica and the
southern part of South America during the period of the seasonal ozone "hole."
Furthermore, elevated surface UV levels at mid-to-high latitudes were observed in the
Northern Hemisphere in 1992 and 1993, corresponding to the low ozone levels of those
years.
40
The international assessment noted the lack of a decadal (or longer) record of accurate
monitoring of surface UV levels: the UV-B network which operated between 1974 and
198S was limited to only a few polluted sites in the USA, hence not representative of die
USA. let alone other locations around the globe. The assessment also noted variations in
UV-B introduced by clouds and other factors precluded the unequivocal identification of a
long-term trend in surface UV radiation. It should be noted that the magnitude of ozone
depletion between 1974 and 1985 over the USA was only about 2% in summer and S% in
winter, a level very difficult to detect given the limited number of sites, local pollution
problems, high variability of UV-B induced by variations in ozone and cloud cover, and
the low sensitivity of the instruments. J. DeLuisi of NOAA has concluded that the signal
from UV-B is so noisy due to day-to-day changes in UV-B, and *he calibration of die
monitors was so flawed, that no reliable trends can be determined from the data. The
UV-B flux may have even increased (as expected) over that time period, but it would not
have been detected by the network ~ it would have been overwhelmed by the calibration
problems. The original data sets and documentation for the network no longer exists, so it
is impossible to reconstruct an accurate data base from the monitoring network.
Recent data, since the international assessment, suggest that is highly unlikely that there is
no long-term trend in UV-B. Statistically significant (2-sigma) UV-B trends during
spring, early summer and late autunm at latitudes between 60 degrees North and 60
degrees South can be derived from TOMS satellite measurements. In addition, satellite
estimated UV-B fluxes agree very well with ground-based measurements for all observing
conditions (cloud plus aerosols and clear sky).
What are the human health impacts of ozone depletion?
o As stated earlier, ozone depletion will lead to increases in the incidence of non-melanoma
skin cancer, melanoma skin cancer, eye cataracts, and a possible suppression of the
immune-response system.
o Let me just discuss briefly just one issue, that of UV-B radiation and non-melanoma skin
cancer. For every 1% sustained increase in UV-B radiation there will be an approximate
2% increase in the incidence of non-melanoma skin cancer in light-skinned people. The
current incidence rate of non-melanoma skin cancer in the United States is approximately
750,000 new cases each year, of which between O.S and 1% of these cases will result in
death. Even those cases diat do not result in death, are a significant cost to individuals
and health care services. Ozone depletion is expected to peak within the next few years at
about 6-7% over Northern mid-latitudes (including the United States) in summer/fall and
about 13-14% in winter/spring. Thus a sustained ozone depletion will lead to a significant
increase (about 1 5%) in the incidence of non-melanoma skin cancer and associated deaths:
clearly an important public health issue for the United States.
41
o Some try, irresponsibly, to trivialize the issue of ozone depletion by noting that an ozone
depletion of the magnitude observed is equivalent to only moving south by a hundred
miles or so. The reason the risk is even this low is the Montreal Protocol and its
amendments and adjustments. Without these international agreements we would be facing
future increases in UV-B radiation of possibly 40-50 percent by the middle or end of the
next century, and the comparable distance to move would be more like a thousand miles
or greater. If there were an increase in UV-B radiation so that people living in Boston
experienced an equivalent of the radiation they expect when they visit Miami, most people
would consider that change to be highly significant. There is a big difference in skin
cancer rates between cities in the northern half of the U.S. and those in the Southern half
For example, the skin cancer rates for fair-skinned males in Albuquerque were approx.
700 per 100,000 versus 150 per 100,000 in Seattle, a factor of 5 increase.
Conclusion
o Human-induced stratospheric ozone depletion is occurring at all latitudes except the
tropics. This results in an increase in ultraviolet radiation at the Earth's surface, which is a
serious human health issue for Americans.
o Those that suggest the Montreal Protocol is not needed or too expensive, clearly must put
a low value on the thousands of future lives saved annually in the U.S. alone.
42
Historical Springtime Total Ozone Record
for Halley Bay, Antarctica (76°S)
400 -
1995
43
SOI ) ill I 'C)i
SrAIION
17--26 AUG 93 272.26 DU
12 OCT 93 91 DU
1 1 OCT 92 105 DU
20
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48
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50
Mr. ROHRABACHER. Dr. Watson, thank you very much.
Dr. Singer, I heard your name mentioned several times. Maybe
you'd like to testify next.
STATEMENT OF DR. S. FRED SINGER, PRESIDENT, THE
SCIENCE AND ENVIRONMENTAL POLICY PROJECT, FAIRFAX,
VA
Dr. Singer. I wish I could give as emotionally charged a presen-
tation as my colleague has just done. But I'll try to be calm and
factual.
I'm a scientist who has worked for a number of years on atmos-
pheric and ozone problems.
My relevant biography is given in the testimony. I've also at-
tached to my testimony a recent peer-reviewed article that I've
written on the ozone issue. It lists further peer-reviewed articles
that I've written in the last few years.
I'm very distressed that Congresswoman Rivers was not able to
find some of my peer-reviewed articles. I think there are about 200
of these in the literature and I'd be glad to supply a list.
But perhaps it's her staff that's at fault. So I should not blame
her for this.
I was asked to supply some examples of lack of scientific integ-
rity in dealing with the ozone CFC issue.
I thought I would list about half a dozen of these and you'll find
them listed in my testimony and hopefully, thoroughly explained.
These are cases where the science was twisted, shaped, in order to
gain certain ideological objectives. There was never a case where
the actual facts were, shall we say, misstated, where there was ac-
tual wrong information presented.
But~it was presented in such a way as to give a misleading im-
pression.
You, ladies and gentlemen, here are being today misled, bam-
boozled, and otherwise manipulated by some of the testimony that
you've just heard.
My job today, I think, is to expose this to you, and I'd like to do
that. I hope there will be many questions to me so that I'll have
a chance to comment in some detail on the way in which the sci-
entific information has been misrepresented to you in order to
achieve certain political objectives.
I'm fortunate to have Dr. Baliunas here. She's the distinguished
research astrophysicist at the Harvard Observatory. She'll be ad-
dressing the issue of ozone depletion, or so-called ozone depletion.
But let me address the issue which is an important one of the
possible or claimed rise or increase in ultraviolet radiation.
You know, the people who believe that ozone has been depleted
are looking very, very hard for some evidence for an increase in ul-
traviolet radiation to prove that ozone has been depleted.
They've not been able to find it.
If you look, for example, at Dr. Watson's testimony on page 7,
you'll find some convoluted language, saying that various factors
have precluded the unequivocal identification of a long-term trend
in surface UV.
What this means is that he has no evidence.
51
Later on he says, it's highly unlikely that there is no long-term
trend in UV-B.
Again, this means that he has no evidence.
But why doesn't he have any evidence for an increase in UV? I'll
tell you why. Because the evidence we have shows that UV-B did
not increase. It decreased. The evidence was published and covers
the period of 1974 to 1985.
Now let's see how he deals with the evidence, how does he ex-
plain it away.
Well, first he says, the instrument is no good. Bad calibration.
Well, when it's pointed out that the instrument is okay, then he
says, well, okay. The instrument is fine, but the record is too noisy.
The UV goes up and down. You can't tell if there's a trend.
When you point out that the same argument applies to ozone, he
then goes to the same argument. He says, well, pollution increased
in the atmosphere £ind that's what absorbed the UV.
But the EPA tells us that pollution has decreased in the United
States as a result of the Clean Air Act, so that's a difficult problem
for him.
Well, fortunately, to the rescue comes a publication in Science
magazine in 1993, claiming that UV-B over Toronto has increased
by up to 35 percent per year. Thirty-five percent per year — that's
a very large trend if it goes on for many years.
We examined that paper. By the way, the paper was supposed
to be peer-reviewed. We published a paper in Science showing that
the analysis was incorrect, based on faulty statistics, and that the
trend of UV-B was zero. Zilch. Nothing. Nada.
There was no trend and the paper is wrong. And it's still being
quoted, not only by Dr. Watson, but also in the Scientific Assess-
ment of 1994 that has been referred to earlier.
Well, after he shows that you cannot detect the UV trend, he
then goes to a nonsequitur. If you can't get it here, you switch to
something else.
The nonsequitur is, well, UV-B has increased in the Antarctic
whenever ozone decreased.
Well, of course it would do that if there's a clear sky. What he
doesn't tell you is that as soon as ozone increases, the UV-B de-
creases.
In other words, it goes up and it goes down.
But if you look at his testimony, you'll find only references to
cases where the UV-B goes up. It's like telling you that it gets
warmer every July and never tells you that it gets colder in Decem-
ber.
It leaves you with the impression that this is going to be a very
hot climate some day.
Finally, there's a suggestion that the satellite instrument, the
TOMS instrument, has measured a UV trend on the surface.
I know something about the instrument. I designed it many
years ago. If you read his testimony carefully, you'll find out that
the UV trend that he talks about is not measured. It's derived from
the TOMS instrument. It is estimated.
In other words, it's calculated. It's not a direct measurement of
UV reaching the surface of the Earth. There simply is no evidence
for this. And this is crucial, I think, because it is UV at the surface
52
of the Earth that's supposed to produce all the harmful health ef-
fects that we're talking about. It's supposed to produce all the skin
cancer that we're talking about, and I hope I'll have a chance later
on to comment on this, but I'd better stop at this point.
Mr. ROHRABACHER. Do you have a 30-second summary that you'd
like to make?
Dr. Singer. Yes, only one point here. You often hear the state-
ment from Dr. Watson and others that the depletion of ozone is
worse than expected. Or that the ozone hole this year is worse than
expected. Or that the increase in UV is worse than expected.
Expectations are based on theory, on calculation.
If you think about the statement for a minute, it sounds awful.
It's very frightening. Isn't it scary — "worse than expected."
What it really means is that the expectation, the theory, is
wrong. Or the observations are wrong. Or, more likely, thej^re both
wrong.
Thank you.
[The complete prepared statement of Dr. Singer follows:]
63
The Jcience t Environmental Policy N^i
4084 UnJversfty Drive, Suite 101
Fairfax. VA 22030-6812
Tel: (703) 934-6940, Fax: (703) 352-7535
S. Ff»d Singer. PrvD.. President
TESTIMONY OF SjfpRED SINGER, PhD"
PRESIDENT, THE SaENCB-A-EI^VIRONMENTAL POLICY PROJECT
Heariog oo "Stretosphoic Ozone: Myths and Realities"
HoQse Science Conunittee, Subconunittee on Eneigy and Environment
September 20, 199S
Mr. Cbainnan, Ladies and Gentleinen.
My name is S. Ftei Singer. I am professor emeritus of environmental adences at die University
at Virginia and tiie founder and president of The Science & Environmental Policy Project in
l^iiftx, Viigioia, a non-paitisan non-profit research group. I Iiold a skepdcal view on the
adequacy of the science dial siyports our coirent stratospheric ozone policy-namely, to phase
oat chlorafloorocaitxuis (GPCk) on an aocelenued schedule.
Vice Ptesident Al Gore keeps lefeoing to scientist skeptics as a "dny minority outside the
mainstxeam." Others tiy to discredit scientist skiq>tic8 by lumping diem together with fiioge
political gfoapt. To counter such misrquesentatlons, let me present my geoeial scientific
qualifications and diose relevam to the ozone issue.
Relevant BadcETOond:
I hold a d^iee in engineering tnm Ohio Stale and a PhJD. in physics from ndnoetoo Umversity.
For mote than 40 yean, I have specialized in atmospheric and space physics. I received a
Special Oommendadon from Rresident Elsenhower for die eady design <tf satellites. In 1962. 1
estaWidwd die U^. Weadier Satellite Service, served as its first director, and leo^ved a Gold
Medal award from die VS. D^artment of Oommeree for this c<MUribntion.
Eaily in my career I devised die instrument used to measure strato^iheric ozone from satellites.
As a DepoQr Assistant Adnnnistrtior of die U.S. Environmental Rrotecdoo Agency in 1971, 1
chaired an intcniepartmetital panel of sdeotlsts loddng into the possible effects on sBatospheric
oaone of a proposed fleet ci tapetsotac transports ^STs). Ours was the first group to examine
possible damage to die ozone bQfer fh»m human activities and look into poteodal health
oooseqoeoces. hichiding skin canoers. During diis period I published the li^pothesis that
54
anthroposenic mettuuie, fixMn cattle raising and rice growing, ooold deplete stratospheric ozone'.
In tbe late 1980s I saved as Chief Sdeotist of the U.S. Depaitment of TYanspoitatloo and also
provided expert advice «> tbe White House on the ozone issue.
gxa^ka of Bailnrea of Scientific Integrity:
Today's hearing on scientific integrity as telated to the strato^heric ozone layer is well timed.
The Unted Nations Enviroiuneat Programme and the secretariat for die Montneal Protocol [oa
Substances diat Deplete die Ozone Layer] designated Sq>tetnber 16 as the fiist anoaal
Intenuoional Dey for the Presenration of the Ozone LiQrer. The White House, spurted on by die
EPA. has extended tiant oelefantioa into a whole wask. This should remind us tfiat ozone
dq>letioo is no longer Just a scientiflc debate; entrenched domestic and intematiooa] bureaucra-
cies, not to meatioa commercial interests, now have a considerable stake in keqiing alive fears
of an ozone catastn^hc
TUs moiniag, I will touch oo seveial topics that relate to the dieme of scientific faitegri^
• Hnt. I want to state deariy diat there is no scientinc consensus on ozone deidetion or its
consequences. "Consensus" is a political concept, not a scientific one. It is used mainly to gain
icasMuanoe for an ideological position and to avoid having to examine the scientific arguments
in detail. Consensus has been claimed also tot die global wanoing issue. The oCBcial ttpon
Crotn the UN-qMosored Intei]govenunental Pnel on dimaie Qiange mentiwis the cxisteaoe of
"minority" views, but the editon could not, or perhaps would not, "accommodate" them*. The
IPOC editors thus achieved "consensus" by ignoring contrary evidence and disseodag views.
Much die same has been true in the ozone issue.
In view of the present policy to ban CPCs by tbe end of 1995, why spcad a lot of energy fighting
A fitit aeconq>in I ddnk die best answer was given by an enviroomeotil activist on an ABC
New9-"ffighdinc" tdevision program in I^ebraary 1994. Michael Oppenhdmcr of the
EnviioaineDtal Defense Pond complained diat "if [skqidcal sdeotists] can ^ die pafalk to
believe that ozone wasn't wordi acting on, diat Aey [the public] were led in die wrong
direcdon>.« then diere it do leasoa fer the ptibUc to beUnre «nytfaing about any envlronnnentil
issue." Given the activist groaps' miserable record of unfounded scares about the global
environment, such a reaction may be warranted.
• Ndd, I want the record to diow diat tbe 1987 Montreal Protocol [on Substances that Dqilete
die Oaone Layer] wis n^odated widiout adequate concern fyr ackntific evideooe. Hie chief
' S. P. Stf^er. "StEitiiVtak Water Vapoor Increase Doe to Hiiman AeliTilia,' N^^
(W71)
* CSMmm e»M|«; Tk //VC SeteMtfk AjMSMMf («dilBd by J.T. Ho^^
^\
55
U.S. negotiator, State Depanment official Richard Benedick, prowDy revealed in his 1991 book.
Ozone Diplomacy, oo page 2: "Pcrhayw tbc most extraordinaty aspect of the treaty was its
iiTq>osition of substantial short-temi economic costs-^against ooproved future dangers— dangers
dial rested on scientific theories laUier than oa fiim data." Again, on page 18: In Joly 1987,
practically on the eve of the final negotiating session in Montreal. NOAA concluded that the
'scientific community is cuneady divided as to whether existing data on ozone trends provides
soffictenc evidence... that a chlorine-induced ozone destruction is occuniAg."
Benedick does not mention the fact that, as late as 1988, published evidence on stratoq>beric
rhlorifK showed no vp^niA trend, tibius indicating that neither CFQs nor other manmade
chemkals were contriboting significantly to the total— over and above known natural sources like
volcanoes and oceans. An axticle by MIT professor Ronald Prinn, in a book edited by Prof.
Sherwood Rowland and puUished in 1988. makes this point quite clear'.
It is apparent from die above quotes diat the negotiators and their scientific supporters were not
ct all inhibitBd by the absence of scientific evldeace-or indeed by the presence of contraiy
infQtxnadon^
• Thini, the self-constituted Ozone Trends Panel first announced die existence of global ozone
depletion in a March 1988 press conference, but did not present Its supporting analysis for review
until omch latei'. A soidy of die OTP data by two independent American scientists, whidi was
widely distributed as a prq>rint, showed cleariy that, even after thev thought thev had
tucoessfullv "tubtracdiwt'' the natural variations by statistical methods, the so-called "depletion
trend" dq>ended on the choice of time inteival-ie.. die year the analysis starts and ends*.
Curiously, this result, which shows die dominance of the la^gje (natural) solar-cycle variation of
ozone, was left otit of a later published paper involving the same authors as collaborators with
' R. G. Prinn, "How Kne die Almospherie Caaoen&atioas of the Halocnboos Chanted?* in The Chanltit
Aamphtrt (P. S. Sowiaad and L S. A. laksca, cds.). pp. 33-4S, John Wiley, New Yodc. 1988.
' In an artkk of i)lBcfa 16. 1995. adeoce editor 11m lUdfoid of ttw Mandwster Gtianfian c^^
paafcaatcdatdietiineofibePRitKolMCOdatiooK "..iess.jtliit dte tioie in the osone wodd wipe out life aO
over die wodd.* S«Kh feais were eaooonged by 'aoAoritative' statoncnts; lUdfiiMd qinles « oC(^
HttiaalSdeMePDandaiian, vanity as late as 1989: It's (enUyiag. If these osooe holes knpgpawiiviifaediis.
Ibeyll eventDtlly eat the wodd.*
' ILA. Kerr, Stienee 239. pp. 1489^1 (Much 2S, 1988): aa account of the ptess conggencc and executive
•nouiiaiy on "dcplelioa' by Ozooe Ttends Ruel.
* WJ. iM and 1> BislMp. of AJDied<Slgoil Gap.: quoted b S J'. Silver. "WhM OooM Be Qmsi^
Oepletk»rfa Qtmalelmpaatf Solar VcfUbOitf (K.H.SdMtientndA.Addns.eds.)NASAPublici<ioo3086.
1990
56
govemmeat scientists^
There is also a stUi umcsolved dispute about die quality of the data themselves. The OTP, and
the sabseqoent UN-sponsored assessment groups, have never grappled with objections published
by two Belghm researchers in 1992*. These scientists showed that the ozone readings were
contaminated by air pollution and termed the reponed ozone trend "fictitious." Because of
simiiar absorption of ultraviolet, deaeases in sulfur dioxide, brought about by reduced industrial
emissions, were being falsely read as decreases in ozone.
Global ozone dq;>letion is sdll a controversial subject Starting with the OTP press conference,
depletion has generally been reported to be "worse than expected." This statement should
produce tiie logical conclusion that the CFC-ozone theory (on which "expectation" must be based)
is wrong, or ^ observatioos are wrong, or they are both wrong.
• FtMBth, another press confiereoce, airasged by NASA on F^tvuary 3, 1992-during crucial
Congressioaal bearings on the NASA budget and well before the end of the series of strato^heric
observadons-implied die threat of an Arctic ozone hole. The resulting nationwide scare led the
Bush WUte House to advance the phaseout of CFCs to December 31. 199S.
The Arctic ozone hole never hiqipeoed-somediing NASA scientists could have predicted at the
time of the press conference. Informatioa leaked to a journalist indicated diat NASA scientists
had midJanuaiy sateDitB data diowing that stratospheric chlorine was already in decline. Yet
the agency went ahead widi the February 3 press conference and refused to reveal this
information and allay ptAlic fears until a second NASA press conference tliree months later, on
April 30^.
• Fifdi, the "smoldnggun'of ozone depletion activists is, of course, an increasing trend of solar
nlttaviolet radiation at the eai^'s sorfsce. All of the published evidence before November 1993
had shown no such trend. Then, a research paper in Science magazine claimed upward trends
^ ILD. Bojhov. L. Bishop. WJ. KIl. OJC Reinsel. and 0.C liao. 'A ttalistical etad aaalysb of revised tottl
Dobaon ooMe data owerihe Northern Reni^iiat,' y. (TaopAjir. X<r. 95, 9785-9807. 1990
*D.DeMiier and H.DeBacker.ltevisioa of 20 years DiAsm Total Ozone Data itf Ucde (Beigluiii): Hciiiioas
Dotaoo Total Oaono IVends BadBoed by Suite Dioxide IVends,' J. Oteplip. R«s^ Vol 97. p^ S921-S937. April
20, 199Z They dcaoostnaeltatteDqbaooeMBe meter can aiisimeiprct<KdownwawlttqidcfSO|polhaion.
tiviog rise to a "Iktitioai* ciDaae (rend. TlKir tfai^ wn ooofitned by a tide 9oiq> ^
Woriohop oTtfielPOC and dwiDt'lOnneAssessaicnt Panel. Hmtwis. May 17-19.1993
* R. BaSey, EcoSemu St. Ktetm's hess. 1993, p.120: aad private coouaonication by dK aoAor
A
67
of as much as 35 percent per year-without giving any estimate of the margin of crroi^'. This
widely touted result, featured in a press release by Science and still being cited by the EPA and
environmental activist groups, was shown to be completely spurious". The analysis was based
nn fjinlty statistiw. thr "nmd" wis mo.
Only later was it learned that the paper had been first submitted to the British scientific journal
Nature, but had been rejected in the peer-review process. It's still somewhat of a mystery how
this article passed the review process of Science.
There is still no evidence for an increased trend of stirface UV to match a putadve ozone
dq)Ietion trend
• Finally, there is the Setlow experiment, which demonstrates that malignant melanoma skin
cancers are mainly caused by a region of the UV spectrum that is not absorbed by ozone and
therefore not affected by changes in the ozone layer^^ When the EPA is not ignoring this
result, it is attacking it on the basis that Setlow experimented with fish and that fish are not
people". (Ironically, the EPA expresses no such qualms when using rats to determine the
carcinogenicity of chemicals.) In the meantime, the EPA has resisted Congressional requests to
revise its cost-beoeSit analysis backing the Montreal Protocol, which was based oo the wholly
unjustified assumption of 3 million additional skin cancer deaths.
Condurion;
The bottom line is this: Cnnently available scientific evidence does not support a ban on the
production of chlorofluorocarbons (CFCs or 6eonsX halons, and especially methyl bromide*^.
There certainly is no Justification for the accelerated phaseout of CFCs, which was instituted in
1992 on nodung more than a highly questionable and widely criticized NASA press conference.
Yet becatise of the absence of full sdendiic debate of the evidence, relying instead on unproven
'* J.B. Kerr and C.T. McBlioy, "Evideooe for Luft Upward IVends of tJIftaviofet-B Radiadoa Uak«d to Omae
Depioliao.- Sdetcc M2, 1032-1Q34 (12 Nov. 1993}
" PJ. Michads, $F. Singer. P.C Knqipeiiberger, * Analyilng olttavioiet-B ladiation: b tfwre a nend? Science
1*4, pp. 1341^ CZ7 May 1994)
'* R. Setlow el al 'Wavdeogtfas efibctive in lAduction of malignant meJaaama' Fnc. ffail. Aevd. Set. USA 90.
«6d64670.Jalyl993
" Letter firom Paul L. Sto^man, EPA, to Coflgiessmao John DooHttie, dated Nov. 9. 1994
'^ Par backup aee aoached pat>licaiion: SJ'. Singer. The Obmc^TC Detede: Hasty Aciioa, Shaky Sckace,*
Tedmohgy: J. FnmkUa ItaOtuu 332A, 61.66, 1995
58
theories, we now have an international treaty that will conservatively cost the U.S. economy some
$100 billion dollars'^.
The history of the CFC-ozone depletion issue is rife with exan^les of the breakdown of scientific
integrity: selective use of data, faulty {plication of statistics, disregaid of contraiy evidence, and
other scientific distortions. The policy before and since the Montreal Protocol has been driven
by wild and irresponsible scare stories: EPA's estimate of millions of additional sldn cancer
1 deaths, damage to immune systems, blind sheep in Chile, the woridwide disappearance of frogs,
plankton death, the collapse of agriculture and ecosystems.
The latest example of "science by press release" is the scare story about a massive ozone hole,
fed to die media in Sept 1995 b)r the Geneva-based Worid Meteorological Organization. "At
its present rate of growth [it] might grow to record-breaking size...." said Riuneo Bojkov, a well-
known WMO alarmist But then again, it might not-according to NASA scientist Paol Newman.
Australian meteorologist Paul Lefamann agrees: The hole will change its shape, volunw, and Uze
daily »a it grows; he concludes that its final size is not predictable by comparing data now with
those of a year ago.
These scare stories caitnot pass what I call the common-sense test: A projected 10 percent UV
iitcrease from a wor^t-case global ozone depletion is the equivalent of moving just 60 miles
closer to the equator", say from Washington, D.C, to Richmond, Virginia. New Yorkers
moving to Florida experience a more than 200 percent increase in UV becanse of the change in
latitude. Why aren't they dropping like flies? Mail-order nurseries in the upper midwest ship
field'grown plants all over the United States. Why don't these plants die?
Scientists involved in ozone research have known these facts from the beginning, but only a few
have acknowledged them puUidy.
" B. Lkherroan, The High Cost tf Cool', Corapetiiive Enjoprlsc Institote. Wad>ington DC. 1994. He
estimates (he tcn-ycar cost for US aiuamobiks alooe between $24 and $49 billion.
** WMO Report "ScieotiSc Assessment of Oxone I>q>Ietion' Global Otone Retearch and Monitoring Frojtel-
Rep( No. 2S. Wodd Kdet Qrganlzadoo, Geneva CH 1211. 1991 (Fig I MO)
Tcclmolosy: Journal o/Tlic Franklin Insiiiiiie. Vol. 332A. pp. 61-66. I99S 1072.9240/95 Sj.OO^-.OO
Princed in ihc USA. All righis rciervcd. Copyrigh( O 199} Cocnizanc Communicacion Corporaiion
COMMENTARY
THE OZONE-CFC DEBACLE: HASTY ACTION, SHAKY
SCIENCE
encs & EnvirervnantaJ Policy Pro|«cl, Fairfax. VA
TF 941 1-260 C(Rtccivtd 27 January 1995: oectpud 16 March 1995)
By iniemacional agreement, (he manufacture of
chlorofluorocarbons (CPCs) is supposed (o cease in the
United Stales and most other developed nations by the
end of 1995. Motorists will face shortages when they try
to recharge their air conditionen; with the cost for repair
or retrofit likely in the multi-hundred dollar range; the
10-y cost for U.S. automobiles is estimated as between
$24 and 549 billion (1). The U.S. Environmental
Protection Agency (EPA), anticipating a potential
consumer revolt, had to persuade a reluctant OuPont
Corporation to rescind its voluntary commitment to
close down its production line by the end of 1994 (2).
(Hoechst AG actually closed down its CFC production
in Germany on April 16, 1994)
Yet in spite of the hardships caused by the hasty
phaseout of CFCs and other suspected ozone-depleting
halocarbons. the EPA has never questioned the
adequacy of the science that forms the basis for its
phaseout policy. The facts are that the scientific
underpinnings are quite shaky: the data are suspect: the
statistical analyses are faulty: and the theory has not
been validated (3,4). The science simply does not
suppon this premature and abrupt removal of widely
used chemicals — at great cost to the economy. This fact
seems finally to have been recognized by legislators: in
early 1995. Republican Congicssman from Texas, Tom
Delay, introduced a bill. H.R. 475, to repeal the
provisions in Title VI of the 1990 Clean Air Act
regulating the production and use of CFCs.
If one examines the history of governmental CFC
policy, one finds that it is based mainly on panicky
reactions lo press releases from EPA, National
Tliis paper was prtpjicd (w ilie sjrnipasjum drdiraifd lo Oixy L.ee Rjy. For
reasons beyond Uie contjol 01' the editor it could not appear in the volume
dedicated to thai topic.
Aeronautics and Space Administration (NASA), and
National Oceanographic and Atmospheric
Administration (NOAA) about skin cancer and possible
Arctic ozone holes — stimulated and amplified by
environmental pressure groups and the media — rather
than on published work that has withstood the scnitiny
of scientific peers. Credence has been given to EPA
"estimates" of millions of extra skin cancer deaths, to
lurid stories about ozone depletion leading to blind
sheep, to the travails of whales in the Antarctic, and to
the worldwide disappearance of frogs and toads. It is
perhaps characteristic of this topic that so many of the
scary announcements have led off with some statement
like: "The depletion of ozone is worse than
expected" — starting with the March 1988 press
conference by the Ozone Trends Panel (5). Yet since
"expectation" must be based on theory, the discrepancy
with observations means, logically, that either the theory
is wrong or the data are wrong, or both are wrong!
For the general public, and even for the tiained
scientist, these scientific controversies are difficult to
sort out. It is indeed a multi-faceted problem, a chain
with many links connecting the release of CFCs into the
atmosphere with the laccurrence of skin cancer. Briefly,
the steps are postulated as follows (6):
1 . CFCs with lifetimes of decades and longer become
well-mixed in the atmosphere, percolate into the
stratosphere, and there release chlorine.
2. Chlorine, in its active form, can destroy ozone
catalyticaily and thereby lower its total amount in the
stratosphere.
3. A reduced level of ozone results in an increased level
of solar ultraviolet radiation reaching the surface of the
earth.
60
S. F. Singer
4. Exposure lo increased UV leads lo increases in skin
cancer.
Each "of these four steps is controversiaj. has not been
sufficiently substantiated, and may even be incorrect
(7,8). One can reasonably conclude that policy is
rushing far ahead of the science.
SCIENTIFIC UNCERTAINTIES AND
CONTROVERSIES
It is generally agreed that natural sources of
iropospheric chlorine (volcanoes, ocean spray, etc.) are
four to five orders of magnitude larger than man-made
sources (9). But it is what gets into the stratosphere that
counts. The debate has degenerated into arguing about
how much chlorine is rained out in the lower
atmosphere (10) rather than measuring whether
stratospheric chlorine is actually increasing.
Contrary to the claims of some skeptics, CFCs do
indeed reach the stratosphere; the secular increase of
fluorine, in the form of HF, as reponed by Belgian
researcher R. Zander, may be sufficient proof (1 1,12).
But as late as 1 987, Zander found no long-term increase
in HCI, suggesting that stratospheric chlorine comes
mostly from natural sources, which are not expected to
increase over time. The situation changed in 1991.
however, when NASA scientist C. Rinsland published
data showing HCI increasing at about half the rate of
HF, suggesting both natural and man-made sources
(13). Yet the Montreal Protocol to freeze CFC
production and roll it back to lower levels was signed in
1987, at a time when published work still indicated
little, if any, contribution from CFCs.
(Earlier aircraft- based observations of HCI increases
between 1978 and 1982 by NCAR researchers Mankin
and Coffey (14) were used to justify a CFC phaseout,
even as late as 1993 (15,16), in spite of the fact that
their data series was judged to be of poor quality and
too short; according to MIT Professor Prinn, their
published rate of increase of stratospheric chlorine
could well be close to zero, in agreement with Zander's
1987 result (17). In any case, Mankin and Coffey
themselves ascribe their observed 1982 increase to the
volcano El Chichon (18) rather than to CFCs).
The question of global ozone depletion has been
bedeviled by doubts about the quality of the data.
Readings from Dobson ground observatories can be
contaminated by long-term trends in SO, pollution of
the lower atmosphere. DeMuer and DeBacker have
demonstrated that the Dobson ozone meter can
misinterpret the downward trend of SO; pollution,
civins rise to a •■fictitious" ozone trend (19). (Their
finding was confirmed by a task group, chaired by
Robert T. Watson, in a Joint Workshop of the EPCC and
the International Ozone .^ssessment Panel in May
1993).
Another, quite separate problem is produced by the
extreme noisiness of the ozone record. To establish the
existence of a small, long-term trend it is necessary to
eliminate the large natural variations, especially also
those correlated with the 1 1 -y sunspot cycle. This is an
impossible task given the shortness of the record and the
virtual absence of data on long-term variations of the
solar far-UV radiation that produces ozone in the upper
atmosphere. The analysis fails a simple lest: The "trend"
is found to depend strongly on the choice of time
interval (20). An additional problem in identifying a
man-made trend arises from long-term trends in sunspot
number, and therefore long-term ozone trends of natuiTil
origin (21).
Thus, the issue of whether the global ozone layer
shows a steadily depleting trend is still controversial.
Satellite data on global ozone content are not subject to
interference from low-altitude pollution, but long-term
calibration drift presents a problem; the TOMS data
from satellites appear to have a calibration drift due to
nonlinearities in the photomultiplier (22). In any case,
the shonness of the record. 1979 to present, makes the
solar-cycle correction problematic (23).
The Antarctic ozone "hole", an annual short-lived
thinning of the layer first identified in 1985, is a genuine
phenomenon whose intensity has increased markedly
since about 1978. Its proximate cause is unquestionably
stratospheric chlorine, but its fate may be controlled
more by climate factors and the presence of particulates
than by the concentration of chlorine itself (24); the hole
may persist even if the chlorine level were to drop
below the 1978 value. In any case, no theoretical
predictions exist that can be tested by future
observations.
Nor is the CFC-ozone theory itself in good shape.
Over the years, its predictions for long-term, global
ozone depletion have varied widely; during the early
eighties the National Academy of Sciences published
values that gradually decreased from 1 8% down to 3%.
Since the discovery of the ozone hole, there have been
no funher quantitative predictions published because it
was recognized that the existing theory could not cope
with the heterogenous destruction processes that
depended more on particulate surface area than on the
level of chlorine (25.26).
The theory could not describe ozone variations
caused by the (hetereogenous) reactions on paniculaies
(volcanic debris, aerosols, etc.) in the lower stratosphere
61
Oione-CFC debacle
and therefore was not able to predict the Antarctic
ozone hole. In the upper stratosphere, where only
gas-phase (homogeneous) reactions take place, the
theory predicts larger changes than are actual ly observed
(27).
There is marked disagreement also among the
satellite ozone data (28): In the upper stratosphere,
trends seen by the SBUV instrument are negative, while
SAGE I and n data show slightly positive trend values;
in the lower stratosphere, SAGE shows much larger
decreases than SBUV — up to 3%-6%/y in the equatorial
region, a result that is difficult to explain from CFC
theory.
In the lower stratosphere, recent model calculations
and observations indicate that chlorine-based ozone
destruction may be rate-limited by the amounts of OH
and HO; radicals (29,30). If borne out, then increasing
stratospheric water vapor — as a result of rising
tropospheric methane from human activities, such as
cattle raising and rice growing^ould play a significant
role in ozone chemistry (31).
CONCERNS ABOUT SKIN CANCER
The major public concern about a possible depletion
of ozone comes from the fear that solar UV-B
(280-320 nm) radiation reaching the surface will
increase, typically by 10%. Yet UV-B intensity
increases naturally by about 5000% between pole and
equator, there is less ozone traversed when the sun is
closer to the zenith (32). Hence a 10% increase at mid-
latitudes translates into moving 60 miles (100 km) to the
south, hardly a source for health concerns.
There has been, of course, a determined search for a
secular increase in UV-B to match the presumed
depletion of ozone. But no such trends had been
observed (33) until publication in November 1993 of a
startling increasing trend, between 1989 and 1993. over
Toronto. Canada (34). Close examination, however,
revealed that this "smoking gun" was mostly smoke.
The authors confused a shon-lived increase at the end of
their record with a long-term trend (35).
The driving force behind the policy to phase out
CFCs has always been the fear of skin cancer,
panicularly malignant melanoma. The EPA has
predicted 3 million additional skin cancer deaths by the
year 2075 as a result of ozone depletion (36,37). But
unlike basal and squamous cell skin cancers, which are
easily cured growths caused by long-term exposure to
UV-B. melanoma does not show the same characteristic
increase towards lower latitudes (38) (Surprisingly,
European data on melanoma incidence show a reverse
latitude effect).
It is clear therefore that the rising incidence of
melanoma over the past 50 y cannot be due to any
changes in the ozone layer. Non-melanoma (basal cell
and squamous cell) skin cancers are clearly linked to
chronic exposures to UV-B, as judged from the
increasing incidence towards lower latitudes: melanoma
exhibits a different epidemiology and often occur on
areas of the body not chronically exposed to the sun.
Yet the clear link to solar exposure suggests that
changes in lifestyle leading to greater exposure to the
sun may be the main cause of melanoma.
A breakthrough in our understanding of the
mechanism of melanoma induction came with the
experiments of Dr. Richard Setlow and colleagues at the
Brookhaven National Laboratory. To measure the action
spectrum of UV radiation for melanoma induction, they
exposed hybrids of the fish genus Xiphophorus to
specific wavelengths in the UV-A and UV-B range. The
animals had been back-cross bred to have only one
lumor-supprcssor gene; inactivation of this gene in a
melanoblast or melanocyte then permits the melanoma
to develop (39). The experimenters found that the action
spectrum (sensitivity per quantum) was reasonably flat
across the UV-B and UV-A regions. Because of the
much greater number of UV-A photons, they conclude
that 90%-95% of melanomas are caused by UV-A (40).
But UV-A is not absorbed by ozone at all. and
therefore melanoma rates would not be affected by
changes in stratospheric ozone. This imponant finding
undercuts one of the main reasons for the Montreal
Protocol and all subsequent regulations (41).
A final point should be emphasized: If people
exposed themselves to sunlight using sunscreens that
merely prevent sunburns (prrxiuced by UV-B), they will
increase their exposure to melanoma-inducing UV-A
radiation. While long-term tanning may be somewhat
ptDtective, episodic or recreational exposures expose
melanocytes to exceptionally high levels of dangerous
UV-A (42). The best protection may be clothing or
avoiding the sun altogether.
POLICY ACTIONS: DUMPING THE MONTREAL
PROTOCOL
The above discussion demonstrates that the scientific
evidence does not support the Montreal Protocol and all
subsequent efforts to phase out CFCs, halons. methyl
bromide, carbon tetrachloride, and other important
chemicals. Substitutes will surely be found, but much
testing will be necessary to establish their safety and
effectiveness (43). Then there is the huge cost,
estimated at over S200 billion worldwide, of replacing
62
S. F. Singer
capital equipment that cannot accept the substitutes
(44), plus the as yet unquantified additional costs of
regulatory uncenaimy, as activists attack many CFC
substitutes as "ozone-unfriendly" and demand their
early phaseout. The American public may not take
kindly to those who are imposing a SI 000 burden on
every household with no obvious beneTit. It will be
interesting to see whether the new scientific results, and
a scrutiny of the older ones, will force also a
re-examination of existing policies.
This scrutiny has already begun. California
Congressman John Doolinle. in an October 18. 1994
letter to EPA Administrator Carol Browner, suggested
that EPA revise its 1987 cost-benefit analysis in light of
the new scientific results on melanoma. In reply, EPA
seems unwilling to accept Setlow's results until
confirmed in a mammalian species, and raised various
other objections. In a private communication to me.
dated November 29, 1994. Setlow points out that both
fish and humans have melanocytes that produce the
pigment melanin, whose absorption of a LTV-A photon
is presumed to lead to DNA damage within the
melanocyte cell. In dealing with the other EPA
objections, Setlow states that "one cannot use
epidemiological data that relate skin cancer to latitude
to determine what wavelengths are important in skin
cancer induction. If the EPA does not understand this
simple point, it should not be involved in cost-benefit
analysis."
Might the U.S. withdraw from the .Montreal
Protocol? "Scientific evidence indicates that CFCs are
causing no substantive damage to our atmosphere."
Congressman DeLay has stated in introducing his bill.
From his frontal assault on the Clean Air Act it is but a
short step to call for U.S. withdrawal from the
international agitement entered into in 1987. ostensibly
to "protect" the global ozone layer (though at the time
there was no hard evidence that it needed protecting).
Withdrawal from the Protocol and canceling the ban on
CFCs may seem improbable at this late stage,
however — in view of the physical, political, and
emotional investments that have been made. _
International bureaucrats. federal regulators,
environmental zealots, and especially chemical
manufacturers are all counting on governments to
abolish these chemicals in favor of substitutes that are
often unproven or nonexistent.
Yet momentum against Montreal is building. In
addition to Representatives DeLay and Doolittle, other
members of Congress, on both sides of the aisle, are
raising concerns about the precipitous phaseout of CFCs
ft'reons). fire-fighting bromocarbons (halons). and the
near-irreplaceable agricultural fumigant methyl
bromide. The concerns could sky-rocket when
motorists find themselves without air-
conditioning — short of paying extortionary prices.
Less satisfactory than dumping Montreal, but more
likely as a first step, might be a delay in the phaseout
date of halocarbons. perhaps returning it to the year
2000. That was the date in effect in 1992 before
President Bush advanced the phaseout, stampeded by a
misleading NASA press conference, which raised fears
of an "ozone hole over Kennebunkport," and a panicky
Senate resolution, spearheaded by then-Senator Al
Gore. Michigan Democrat John Dingell initiated an
inquiry into the press conference that started it ail, but
has failed to follow through. Perhaps the time has come
to complete his investigation into the events of February
1992.
The absence of a sufficient scientific base for the
ozone issue is not yet widely recognized, and a
halocarbon phaseout is by now well supported by
entrenched constituencies, including even some
scientists who have staked their reputation and research
budgets on this issue. Nevenheless, it is important for
the future of scientific inquiry to permit free and open
debate on the shortcomings of the CFC theory and the
other scientific "facts" that have been used to shore up
the Montreal policy. This will take time, however, and
some attention by the Congress.
The trend in recent years has been towards stifling
debate by various means: denial of research funds to
younger academic researchers who hold
"unconventional" views; the muzzling of senior
scientists in government service; even the dismissal of
federal appointees who boldly suggest that theories be
validated by measurements. It is in this climate of
intimidation and ad hominem attacks that Congress has
been vainly trying to get at the facts. Yet with the
federal research budget for "global change" now at the
level of $2.1 billion a year — topping even the budget of
[ihe National Cancer Institute — it should not be too
lifficuli to find the answers.
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stratospheric ozone? Science 263: 71-75; 1994.
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in siiu measurements of OH. HO.. NO. NO;. CIO. and BtO.
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of Ultraviolet-B radiation linked to ozone depletion. Science
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S. F. Singer
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42. Setlow, R. B.: Woodhead. A. D. Temporal changes in the
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43. Zurer.' P. Acetic otone levels predicted to decrease. Chem
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conditionine equipment? CRS-Libniry of Congress. Repon for
Congress 93-2825. April 1993.
65
Mr. RoHRABACHER. Dr. Albritton.
STATEMENT OF DR. DANIEL L. ALBRITTON, DIRECTOR, AER-
ONOMY LABORATORY, ENVIRONMENTAL RESEARCH LAB-
ORATORIES, NOAA, BOULDER, CO
Dr. Albritton. Thank you, Mr. Chairman, Members of the Sub-
committee.
My name is Dan Albritton. I'm director of NOAA's Aeronomy
Laboratory in Boulder, Colorado.
For over 30 years, our laboratory has studied atmospheric chem-
istry, including the chemistry of the ozone layer.
In addition, in the past several years, I've served as co-chair,
along with my colleague. Dr. Watson, of the Ozone Science Assess-
ment Panel of the United Nations Environment Program.
Our job there has been to coordinate the preparation of the sci-
entific assessments of the world-wide ozone science community.
In these two capacities, I certainly appreciate the invitation to
appear before the Subcommittee and to summarize the current un-
derstanding that the world-wide ozone community has of ozone de-
pletion.
Let me underscore right at the outset that the summary that I'm
about to give you is not my own assessment. It is indeed the state-
ment of the vast majority of the active and practicing world's ozone
researchers regarding the current state of understanding of ozone
depletion based upon their own results and their own laboratories,
their field observations and their atmospheric monitoring and their
theoretical modelling.
As part of the advice to world government's on the ozone layer,
this ozone community has prepared a series of such state of under-
standing assessments.
In 1985, they prepared this summary, which was used as input
by governments for decisions under the Montreal Protocol in 1987.
In 1989, they updated their ozone understanding for the discus-
sions of governments in the London Amendment in 1990. And in
1991, they updated it further to describe the new findings over the
last years. Aiid that was input to the Copenhagen Amendments in
1992.
And now, as you have already cited, the world science community
has summarized a current viewpoint on ozone depletion and its ex-
ecutive summary is the article in the short book that you have as
part of your package.
These periodic assessments by the community have been deemed
to have very high value. They are, first of all, scientific documents.
They're based upon the published extensive scientific literature
read by colleagues world-wide.
Therefore, they are a solid basis for decision-making, in contrast
to anecdotal statements or privately published viewpoints.
They are pure science. The community makes no policy rec-
ommendations. That's the job of others, like yourselves, that are
entrusted with the public welfare.
Secondly, these are majority statements. In fact, the very, very
vast majority. This assessment was prepared by 250 scientists
world-wide and peer-reviewed by 150 others.
66
It's therefore a touchstone of the opinion of the large community.
This is in contrast to the sporadic and separate statements reflect-
ing the opinions of either one person or a small group of individ-
uals.
Fourthly, it's an international assessment and it draws from the
world scientific community — all nations, all viewpoints, and there-
fore, international problems can be addressed on a common playing
field.
And finally, the scientific scope is comprehensive. Both the natu-
ral changes in ozone and the human-induced changes in ozone are
considered together. And that's much more comprehensive than a
single statement about a single observation or a single publication.
Let me indicate to you the four key conclusions from this. And
I'll do it in a graphical form to supplement the points that my col-
league. Dr. Watson, mentioned.
The first point is that very large seasonal depletions of the ozone
layer continue year after year to be observed in Antarctica. Forty
years of Antarctic ozone data records show that this began in the
1970s and has grown larger since then.
This first chart shows the normal ozone layer as the solid line
and the dashed line shows what's happened during the ozone hole.
The hatched area indicates the ozone that's lost over Antarctica
every year.
As Dr. Watson mentioned, the cause of this is certain. It's the an-
thropogenic man-made compounds of chlorine and bromine, in com-
bination with the special conditions of Antarctica, that has acceler-
ated the ozone depletion there, in contrast to elsewhere.
Mr. ROHRABACHER. Dr. Albritton, could I just stop you right
there for one second? I want to clarify that point.
Dr. Albritton. Certainly.
Mr. ROHRABACHER. You're saying that the natural — you just said
it was caused by man-made.
Dr. Albritton. That's right.
Mr. ROHRABACHER. You're suggesting, then, that natural causes
do not contribute to this?
Dr. Albritton. Natural causes are not the source of the down-
ward trend and growing size of the ozone hole year by year.
Mr. ROHRABACHER. Okay. Thank you.
Dr. Albritton. The evidence for this are direct observations that
the ozone-depleting compounds are 100 times larger in Antarctica
than one would expect without the special conditions of Antarctica
and the chlorine there.
Secondly, in every place that these compounds are high, ozone is
low.
And thirdly, that these ozone losses and high depleting com-
pounds appear in the presence of the ice particles that accelerate
the chlorine effect in Antarctica.
The second point I wanted to underscore visually with you is that
ozone depletion continues to be observed by the eye over much of
the globe.
The second chart shows how the ozone levels have changed over
the past 30 years of observations from the ground-based network.
The top box gives the raw data that these instruments take and
in that you can see the very clear, reproducible, year-by-year an-
67
nual cycle of ozone simply because, like much of the planet, ozone
depends in part on solar activity.
The lower panel shows the data after this well-known annual
cycle and other variations of natural causes like solar activity and
dynamics have been taken out.
My point is, regardless of which one you look at, the downward
trend of the last 15 years is clear.
The third point that I wanted to underscore with you is that
when ozone is depleted above, ultraviolet radiation increases at the
surface.
The third chart shows data taken over long time periods that in-
dicate that any time ozone goes down, as you move toward the left,
that ultraviolet radiation goes up. And those changes are very close
to what one would expect from the scattering of ultra-violet radi-
ation and the absorption by ozone. And therefore, it is an absolute
certainty that if one reduces ozone overhead, you will increase the
ultra-violet radiation at the surface.
The final point I wanted to make is looking ahead to the future.
Point number four. The maximum ozone losses will likely occur
in the next ten years, and thereafter our ozone layer will slowly re-
cover. And let me explain what I mean by that.
This chart shows what has been. It also shows what might have
occurred. And thirdly, it shows what is now anticipated if compli-
ance with our international agreements is maintained.
In particular, solid curve on the left shows the observed and
measured growth of the ozone depleters since 1950 up until
present.
That means the burden of atmospheric chlorine has increased
four times over the natural levels. If there had been no agreed-
upon change in the production of those, the upper dotted curve in-
dicates how chlorine would have grown in the atmosphere had
there been no Montreal Protocol.
And finally, the dashed curve on the lower bottom scale on the
right indicates what one would expect for atmospheric chlorine if
there is full compliance with agreements that are to date.
Notice that that recovery is slow, and this is a very crucial
point — that once placed in the atmosphere, CFCs and other com-
pounds live a very long time. They outlive us. And therefore, even
if decisions are made now, the recovery takes a very long time. And
this indicates the point that if one waits, two larger effects on
downward ozone trend are observed to take any actions or to have
reversed actions.
It implies that the consequences of that will continue well into
the next century.
In summary, Mr. Chairman, let me just note that this hearing
actually began about 20 years ago, when scientists recognized the
possibility that our own actions could inadvertently effect the ozone
layer. And over that period, some of the world's brightest and most
productive atmospheric scientists have sharpened the picture of
that initial point.
Several of those scientists are in the U.S. National Academy of
Sciences because of their ozone research. They have focused on un-
derstanding that problem and they have focused on telling you and
others their story based on the world-wide opinion of scientists.
68
And so I conclude by noting that while I am speaking for them,
it is the world-wide ozone research community that you just heard
from.
Thank you, sir.
[The complete prepared statement of Dr. Albritton (and the Exec-
utive Summary) follow:]
/^ TESTIMONY OF \
(nttjr>/^vrF.T. t. AT.HRmroN
DIRECTOR, AERONOMY LABORATORY
ENVIRONMENTAL RESEARCH LABORATORIES
NATIONAL OCEANIC AND ATMOSPHERIC ADMINISTRATION
U. S. DEPARTMENT OF COMMERCE
BEFORE THE
SUBCOMMITTEE ON ENERGY AND ENVIRONMENT
COMMITTEE ON SCIENCE
20 SEPTEMBER 1995
Mr. Cfaainnan and Members of the Subcommittee:
My name is Dan Albritton. In brief, I am Director of NCAA's Aeronomy Laboratory
in Boulder, Colorado, which studies the cheanistiy and dynamics of the Earth's atmosphere.
I am also Cochair, along with Dr. Robert Watson (USA) and Dr. Piet Aucamp (South
Afiica), of the Ozone Science Assessment Panel of the United Nations Environment
Programme, which provides scientific input to the Montreal Protocol on Substances that
Deplete the Ozone Layer. In these two capacities, I appreciate this opportunity to appear
before your Subcommittee to discuss the scicntiiic understanding of stratospheric ozone
depletion.
As you requested, I will focus this testimony on the scientific understanding of the
ozone layer and of the impact of human activities on it. This text will summarize three
aspects. (1) the series of scientific assessments that the world ozone research commimity
has made of the state of that understanding. (2) the key points of the current scientific
understanding of the ozone layer that were described in the most recent of those assessment
reports, and (3) answers to common questions about ozone that were prepared as part of the
"Scientific Assessment of Ozone Depletion: 1994".
L SCIENTIFIC ASSESSMENTS BY THE WORLD RESEARCH COMMUNITY
In 1994, the worldwide ozone-science research community prepared the seventh in their
series of assessments of the scientific vmdcrstanding of ^e Earth's ozone layer and its
70
relation to hiwnanlfinH- "Scientific Assessment of Ozone Depletion: 1994", pp. 580. (Copies
are available for the Subcommittee members, if desired.) This as.ses«mient report vsdll be
part of the information \xpoa. which the Parties to the United Nations Montreal Protocol will
base dieir fixture decisions regarding protection of the stratospheric ozone layer. There are
two companion reports to this scientific assessment They focus on (i) the environmental'
and heal^ effects of ozone layer depiction and on (ii) the technology and economic
iii^>lications of mitigation approaches.
This series of scientific reports prepared by the world's leading experts in the
atmospheric sciences under the intematioiuil auspices of the World Meteorological
Organization (WMO) and the United Nations Environment Programme (UNEP) are listed
below. The chronology of those scientific assessments aitd the relation to the international
policy process are summarized as follows:
Scientific Assessment
'The Stratosphere 1981 Theory and
Measuremems". WMO No. 11.
"Atmospheric Ozone 1985". 3 vol.
WMO No. 16.
Year
1981
Policv Process
1985
Vienna Convention
1987
Montreal Protocol
1988
1989
1990
1991
1992
1992
1994
London Amendment
Copenhagen Amendment
"Internationa] Ozone Trends Panel Report 1988"
2 vol. WMO No. 18.
"Scientific Assessment of Stratospheric Ozone:
1989". 2 vol. WMO No. 20.
"Scientific Assessment of Ozone Depletion:
1991". WMO No. 25.
"Methyl Bromide: Its Atmospheric Science,
Technology, and Economics" (Assessment
Supplement). UNEP (1992).
"Scientific Assessment of Ozone Depletion:
1994". WMO No. 37.
(1995) Vienna Amendment (?)
71
The genesis of Scientific Assesanent of Ozone Depletion: 1994" occuned at the Fourth
meeting of the Conference of die Parties to the Montreal Protocol in Copenhagen,
Denmark, in November 1992, at which the scope of the scientific needs of the Parties Nv-as
defined. The formal planning of the present report was a workshop m 1993 at which an
intertiationa] steering group crafted the outline and suggested scientists from the world
community to serve as authors. The first drafts of the ch^ters were examined at a
meeting in early 1994 at which the authors and a small number of international experts
improved the coordination of the text of the chapters.
The second draft was sent out to 123 scientists worldwide for a mail peer review.
These anonymous comments v«re considered by the authors. At a meeting in Switzerland
during the summer of 1994, the responses to these mail review comments were proposed by
the authors and discussed t^ the 80 participants. Final changes to the chapters were
decided i^ion, and the Executive Summary was prepared by the participants. The ^oup
also focused on a set of questions commonly asked about the ozone layer. Based upoa the
scientific understanding represented by the assessments, answers to these common questions
were prepared.
As the report documents, the "Scientific Assessment of Ozone Depletion: 1994" is the
product of 29$ scientists firom 36 countries, rqvesenting the developed and developing
world, who contributed to its preparation and review (230 scientists prqiared the report and
147 scientists participated in tlie peer review process). What follows in this testimony is a
summary firom the report of their current understanding of the stratospheric ozone layer and
its relation to humankind.
While the "Scientific Assessment of Ozone Depletion: 1994' is a scientific document,
its value to decision makers is considerable. The reasons for this arc several fold:
o It is strong single concise statement from the large majority of the atone sclent^
community. In the assessment, the magor representatives of the ozone research community
speak at one time and one place r^arding the current understanding of ozone depletion.
The report, djctefore, is a c^nmon reference point for decision makers, in contrast to
sporadic and separate statements reflecting the opinions of one person or a few individuals.
o It is an international scientific assessment. With it, all nations have a common basis of
scientific input for their decision making, as opposed to several national statements.
Vi^iere appropriate, scientists &om developing countries are involved in preparing the
assessment to the fullest extent possible.
o The scientific scope is comprehensive. With the report, decis ion makers have available
72
a single, homogeneous sununaiy of the current scientific understanding of the whole ozone-
change phenomenon, ranging from the agents that cause change to the ozone-layer
responses. This is more uscfiil than separate reviews of components of the phenomenon
done at dififercnt times and perhaps for different purposes.
0 Both natural and human-Induced ozone-layer changes are considered In contrast to
considering only the perturbation of the ozone layer by human activities, the assessmert
places that human-induced change in the context of the observed and predicted changes
thai are a natural part of the ozone layer. The comparison of the two affords immediate
and straightforward insight into the significance of the human-induced perturbations relative
to the natural variations.
73
XL RECENT MAJOR SdENTIFIC FINDINGS AND OBSERVATIONS
The laboratory mvestigations, atmospheric observations, and theoretical and modeling
studies of the past few years have provided a deeper understanding of the human-influenced
and natural chemical changes in the atmosphere and their relation to the Earth's
stratospheric ozone layer and radiative balance of the climate system. The "Scientific
Assessment of Ozone Depletion; 1994" reported several key ozone-related findings,
observations, and conclusions and are the basis for the points summarized below.
Changes in Ozone-Dq>lcting Gases
; o The atmospheric growth rales of several major ozone^iepUting substances have slowed,
derrtonstrating the expected impact of the Montreal Protocol and its Amendments and
Adjustments. The abundances of the human-produced chlorofluorocarbons (CFCs), carbon
tecrachloricic, methyl chloroform, and halons in the atmosphere have been monitored at
global ground-based sites since about 1978. Over much of that period, the annual growth
rates of these gases have been positive. However, the data of recent years clearly show that
the growth rates of CFC-ll, CFC-12, halon-1301, and halon-1211 are slowing down. The
abundance of carbon tetrachloride is actually decreasing. The observed trends in total of
these chlorine-containing compounds are consistent with reported production data,
suggesting less emission than the TTWYinmim allowed under the Montreal Protocol and its
Amendments and Adjustments. Peak statospheric tot^ chlorine/ bromine loading in the
troposphere, most of which is human-produced, is expected to occur in 1994, but the peak
in tbe stratospheric will lag by about 3-5 years. Since the stratospheric abundances of
chlorine and bromine arc expected to continue to grow for a few miore years, increasing
global ozone losses are predicted (other things being equal) for the remainder of the decade,
with gradual recovery in the 21st century.
o The atmospheric abundances of several of the CFC substitutes are increasing, as antidpatexi
With phaseout dates for the CFCs and other ozone-depleting substances now fixed by
international acgirrments, several Kydrochlorofluorocarbons (HCFCs) and
hydrofluorocarbons (HFCs) are being manu£uxured and used as subsritutes. The
atmospheric growth of some of these compounds (e.g., HCFC-22) has been observed now
for several years.
o Methyl bromide continues to be viewed as a significant ozonedepleting compound
Increased attention has been focused upon the ozone-depleting role of methyl bromide.
Three potentially major anthropogenic sources of atmospheric methyl bromide have been
jHfnfififd (soil fumigarion, biomass burning, and the exhaust of automobiles tising leaded
74
gasoline), in aiidicion to the natural oceanic source. Wkile the magmtude of the
atmospheric photochemical removal is well understood, there are significant uncertainties
in quantifying the oceanic sink for atmospheric methyl bromide. The Ozone Depletion
' Potential (ODP) for methyl bromide is calculated to be about 0.6 (relative to an ODP of 1
for CFC-U).
' Changes in Midlatitude and Equatorial Ozone Abundance
o Downward trends in total<olumn ozone continue to be observed over much of the globe,
and their magnitudes are larger than those predicted by numerical ozone-loss models. Decreases
in ozone abundances of about 4 - 5% per decade at midlatitudes in the Northern and
Southern Hemispheres continue to be observed by both ground-based and satellite-borne
monitoring instruments. At midlarintdrt, the losses continue to be miich larger during
winter/spring than during summer/^ in both hemispheres, and the depletion increases
with latitTjde, particularly in the Southern Hemisphere. Little or no downward trends are
observed in the tropics (20#N - 20#S). While the current two-Himrnsiooal stratospheric
models simulate the observed trends quite weU during some seasons and latitiides, they
imderestimate the trends by factors of up to three in winter/spring at mid- and high
latitudes. Several known atmospheric processes that involve chlorine and bromine and that
affect ozone in the lower stratosphere are difficult to model and have not been adequately
incorporated into these models.
o Record low global ozone levels were measured over the past two years. Anomalous ozone
decreases were observed in the midlatitudes of both hemispheres in 1992 and 1993. The
Northern Hemispheric decreases were larger than those in the Southern Hemisphere.
Globally, ozone values were 1 - 2% lower than would be cxpeaed from an extrapolation of
the trend prior to 1991, allowing for solar-cycle and periodic meteorological effects. The
1994 global oz6^ levels are returning to values closer to those expected from the longer-
term downward trend.
o The stratosphere was temporarily perturbed by a mapr volcanic eruption. The eruption of
Mt. Pinatubo in 1991 led to a large increase in sulfate aerosol in the lower stratosphere
throughout the globe. Reactions on sulfate aerosols resuhed in significant, but temporary,
changes in the cbcmiral pardtioning that accelerated the photochemical ozone loss
associated with reactive hydrogen, chlorine, and bromine compounds in the lower
stratosphere in midlatitudes and polar regions. These and other recent scientific findings
strengthen the conclusion of the previous assessment that the weight of scientific evidence
suggests that the observed taiddie- and high-laritude ozone losses are largely due to
75
anthropogenic chlorine and bromine compounds. The observed 1994 recovery of global
ozone is qualitatively consistent with observed gradual rediictions of the abundances of
these volcanic particles in the stratosphere.
Changes in Polar Ozone
o The Antarctic ozone "holes" of 1992 and 1993 were the most severe on record. The
Antarctic ozone "hole" has continued to occur seasonally every year since its advent in the
late-1970s, with the occurrences over the last several years being particularly pronounced.
Satellite, balloon-borne, and ground-based monitoring instruments revealed that the
Antarctic ozone "holes" of 1992 and 1993 were the biggest (arcal extent) and deepest
(rpipipn'yn amounts of ozone overhead), with ozone being locally depleted by more than
99% between about 14 - 19 kilometers in Oaober, 1992 and 1993. It is likely that these
larger-than-usual ozone depletions could be attributed, at least in part, to sulfate aerosols
from Mt. Pinatubo increasing the effectiveness of chlorine- and bromine-catalyzed ozone
destruaion. A substantial Antarctic ozone "hole' is expcaed to occur each austral spring
for many more decades because stratospheric chlorine and bromine abundances will
approach the pre-AntarctioK)zone-"hole' leveb (late- 1970s) very slowly during the next
century.
o The conclusion that human-produced Marine and bromine compounds, coupled with surface
chemistry on natural polar strazospheric particles, are the cause of polar ozone depletion has
been furxher strengthened Laboratory studies have provided a greatly improved
understanding of how the chemistry on the surfaces of ice, nitrate, and sulfate particles can
increase the abundance of ozone-depleting forms of chlorine in the polar stratospheres.
FurtherxDore, satellite and in situ observations of the abundances of reactive nitrogen and
chlorine compounds have improved the explanation of the different ozone-altering
properties of the Antarctic and Arctic
o Ozone losses have been detected in the Arctic winter stratosphere, and their links, to chlorine
and bromine chemistry have been established Studies in the Arctic lower stratosphere have
been expanded to include more widespread observauons of ozone and key reactive species.
In the late-wtnter/early-spring period, additional chemical losses of ozone up to 15 - 20% at
some aktcudes are deduced from these observations, particularly in the winters of 1991/2
and 1992/3. Model calculations constrained by the observations arc also consistent with
these losses, increasing the confidence in the role of chlorine and bromine in ozone
destruction. The inteiannual variability in the photochemical and dynamical conditions of
the Arctic polar voncx continues to limit the ability to predia ozone changes in future
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years.
Ozone Depletion and Radiation
o The link between a decrease in stratospheric ozone and cm increase in surface ultraviolet
(UV) raSation has been further strengthened. Measurements of UV radiation at the surface
under clear-aky conditions show that low overhead ozone yields high UV radiation and in
the anjoiint prediaed by radiaiive-inmsfer theory. Large increases of stirface UV are
observed in Antaraica and the southern part of South America during the period of the
seasonal ozone "hole." Fmthermore, elevated surface UV levels at mid-to-high latitudes
were observed in the Northern Hemisphere in 1992 and 1993, corresponding to the low
ozone levels of those years. However, the lack of a decadal (or longer) record of accurate
monitoring of surface UV levels and the variation introduced by clouds and other faaors
have precluded the unequivocal identification of a long-term trend in surface UV radiation.
o ■ Stratospheric ozone losses cause a ghbaltnean negative radiative forcing of the dimate
system. In the 1991 scientific assessment, it was pointed out that the global ozone losses
that were occurring in the lower stratosphere caused this region to cool and result in less
radiation reaching the surface-troposphere system. Recent model studies have strengthened
this picture. A long-term global-mean cooling of the lower stratosphere of between 0.25
and 0.4 degrees Celsiijs per decide has been observed over the last three decades.
Calculations indicate that, on a global mean, the ozone losses between the 1980 and 1990
offect about 20% of the radiative forcing due to the wcU-mixing greenhouse-gas bcrcases
during that period (i.e., carbon dioxide, methane, nitrous oxide, and halocarbons).
Future Ozone Changes
The research findings of the past few years that are summarized above have several
major implicadons as scientific input to governmental, industnai, and other choices
re^uding hunuui-infhicnced substances that lead to depletion of the stratospheric ozone
layer and to changes of the radiative forcing of the climate system:
o The Montreal Protocol arid its Amendments and Adjustments are reducing the impact of
anthropogenic halocarbons on the ozone layer and should eventually elimirtate this ozone
depletion. Based on assumed compliance with the amended Montreal Protocol
(Copenhagen, 1992) by all nations, the stratospheric chlorine abundances will continue to
grow from their current levels to a peak, around the turn of the century. The future total
bromine loading will depend upon choices made regarding future human producaon and
emissions of methyl bromide. After around the turn of the century, the levels of
stratospheric chlorine and bromine will begin a decrease that will continue into the 21$t
77
aiui 7?n^ cencuries. The rate of decline is dictated by the long residence times of the
CFCs, carbon tetrachloride, and halons. Global ozone losses and the Antarctic ozone
"hole" were first discernible in the late 1970s and are prediaed to recover in about the year
2045, other things being equal. The recovery of the ozone layer would have been
impossible without the Amendments and Adjustments to the orig^al Protocol (Montreal,
1987).
o Peak gU>bal ozone losses are expected to occur during the next several yean. The ozone
layer will be most affected by human-influenced perturbations and susceptible to natural
variations in the period around the year 1998, since the peak stratospheric chlorine and
bromine abundances are expected to occur then. Based on extrapolation of current trends,
observations suggest that the maximum ozone loss, relative to the late 196Qs, will likely
be:
(i) about 12 - 13% ai Northern midlaticudes in winter/spring (i^., about 2.5% above
current levels);
(ii) about 6 - 7% at Northern midlatitudes in summer/fall (i.e., about 1,5% above
current levels); and
(iii)about 11% (with less certainty) at Southern nudlatitudes on a year-round basis (Le.,
about 2.5% above current levels).
Stich changes would be accompanied by 15%, 8%, and 13% increases, respectively, in
surface erythemal radiation, if other influences such as clouds remain constant. Moreover,
if there were to be a major volcanic eruption like that of Mt. Pinatubo, or if an extremely
cold and persistent Arctic winter were to occur, then the ozone losses and UV increases
could be larger in individual years.
o Approaches to lowering stratospheric chlorine and bromine abundances are limited.
Further controls on ozone-depleting substances would not be expected to significantly
change the fipiing or the magnitude of the peak stratospheric halocarbon abundances and
hence peak ozone loss. However, there are four approaches that would steepen the initial
fall from the peak halocarbon levels in the early decades of the next century:
(i) If emissions of methyl bromide from agricultural, structural, and industrial activities
were to be elisoiiuted in the year 2001, then the integrated effective futiire chlorine loading
above the 1980 level (which is related to the cumulative future loss of ozone) is prediaed
to be 13% less over the next 50 years relative to full compliance to the Amendments and
Adjustments to the Protocol.
^ If emissions of HCFCs were to be totally eliminated by the year 2004, then the
integraced effective future chlorine loading above the 1980 level is predicted to be 5% less
over the next 50 years relative to full compliance with the Amendments and Adjustsoents
to the Protocol
Qii)If halons preseiuly contained in existing equipment were never released to the
78
azmosphere, then the integrated effeaive future chlorine loading above the 1980 level is
prediaed to be 10% less over the next 50 years relative to full compliance with the
Amendments and Adjustments to the Protocol.
pv) If CFCs presently contained in existing equipment were never released to the
atmosphere, then the integrated effective future chlorine loading above the 1980 level is
prediaed to be 3% less over the nea 50 years relative to full compliance with the
Amendments and Adjustments to the Protocol.
o Failure to tuihtre to the intfmaiiorud agreements trill delay recovery of the ozone layer, li
. there were to. be additional production of CFCs at 20% of 1992 levels for each year
through 2002 and ramped to zero by 2005 (beyond that allowed for coimtries operating
tinder Article 5 of the Montreal Protocol), then the integrated effective future chlorine
loading above the 1980 level is predicted to be 9% more over the next 50 years relative to
full compliance to the Amendments and Adjustments to the Protocol.
p Many of the substitutes for the CFCs and halons are also notable greenhouse gases. Several
CFG and halon substitutes arc not addressed under the Montreal Protocol (because they do
not deplete ozone), but, because they are greenhouse gases, fall under the purview of the
Framework Convention on Climate Change. There \s a wide range of values for the
Global Warming Potentials (GWPs) of the HFCs (150 - 10000), with about half of them
having values comparable to the ozone-depleting compounds they replace. The
perfluorinated compounds, some of which are being considered as substitutes, have very
large GWPs (e.g., 5000 - 10000). These are examples of compounds whose current
atmospheric abundances are relatively small, but are increasing or could increase in the
future.
o Consideration of the ozone thattge will be one necessary ingredient in ttnderstanding climate
change. The extent of our ability to attribute any r\imite change to specific causes will
likely prove to be important scifntifir input to decisions regarding predicted human-
inducttl ?nflii^n/-i»t on the rMm^tt' system. Changes in ozone since pre-industrial times as a
result of human activity are believed to b«ve been a significant inflnmrr on radiative
forcing; this human influence is t-rprrtfA to continue into the foreseeable future.
m. COMMON QUESTIONS RAISED ABOUT THE OZONE LAYER
The above points «nmman'y«> the current scientific undemanding of the ozone layer and
Its deletion by human-produced cfaenicab. But often more-general questions arise - for
OBtapit, by the public - aboot this environmental issue. The "Scientific Assessment of
Ozone Dq>letioas: 1994* also addressed the information needs of this aodienoe by
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79
including a set of common questions about ozone, with answers by the scientific
community prepared for a general readership. This section of the assessment report is
attached (without figures) as Aimex 1 to chis testimony.
Mr. Chairman, this concludes my prepared text. I would be pleased to answer any
questions that you or the Subcommittee may have.
. 11
80
ANNEX 1. COMMON QUESTIONS ABOUT OZONE
Ozone is exceedingly rare in our atmosphere, averaging abom 3 molecules of ozone for
every ten million air molecules. Nonetheless, atmospheric ozone plays vital roles that
belie its small numbers. This Appendix to the "World Meteorological
OrganizaiionAJnited Nations Environment Programme (WMO/UNEP) "Scientific
Assessment of Ozone Depletion: 1994* answers some of the questions that are most
commonly asked about ozone and the changes thai have been occurring in recent years.
These common questions and their answers were discussed by the 80 scientists from 26
countries who participated in the Panel Review Meeting of the "Scientific Assessment of
Ozone Dq>lction: 1994." Therefore, this information is presented by a large group of
experts from the international scientific community.
Ozone is mainly foiind in two regions of the Earth's atmosphere. Most ozone (about
90%) resides in a layer between approximately 10 and 50 kilometers (about 6 to 30 miles)
above the Eanh's surface, in the region of the atmosphere called the stratosphere. This
stratospheric ozone is commonly known as the 'ozone layer." The remaining ozone is in
the lower region of the atmosphere, the troposphere, which extends from the Earth's
surface up to about 10 kilometers.
"While the ozone in these two regions is chemically identical (both consist of three
oxygen atoms and have the chemical formula "Oj"), the ozone molecules have very
different effects on humans and other living things depending upon their location.
Stratospheric ozone plays a beneficial role by absorbing most of the biologically
damaging ultraviolet sxmlight called UV-B, allowing only a small amount to reach the
Earth's surface. The absorption of UV radiation by ozone creates a source of heat, which
actually forms the stratosphere itself (a region in which the temperature rises as one goes to
higher altitudes). Ozone thus plays a key role in the temperature structure of the Earth's
atmosphere. Furthermore, without the filtering aaion of the ozone layer, more of the
Sun's UV-B iiuliation would penetrate the atmosphere and would reach the Earth's surface
in greater amounts. Many experimental studies of plants and animals, and clinical studies
of hiu:ians, have shown the harmful effects of excessive exposure to UY-B radiation (these
are discussed in the WMO/UNEP reports on impacts of ozone depletion, which are
companion documents to the WMO/UNEP scientific assessments of ozone depletion).
At the planet's surface, ozone comes into direct contact with life-forms and displays its
destructive side. Because ozone reacts strongly with other molecules, high levels are toxic
to living systems and can severely damage the tissues of plants and animals. Many studies
have documented the harmful effects of ozone on crop production, forest growth, and
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81
. iiunun licalrh. The substantial negative effeas of sxir^ce-level tropospheric ozone from
tbis (iiroct toxiocy contrast with the benefits of the additional filtering of UV-B radiation
that it provides.
With these dual aspects of ozone come two separate environmental issues, controlled by
' different forces in the atmosphere. In the troposphere, there is concern about increases in
ozone.' Low-lying ozone \s a key component of smog, a familiar problem in the
atmosphere of many cities around the world. Higher than usual amounts of sur^u^level
ozone are now increasingly being observed in rural areas as welL However, the ground-
level ozone concentrations in the smoggicst cities are very much smaller than the
ooncentrations routinely found in the stratosphere.
There is widespread scientific and public interest and concern about losses of
stratocpfaeric ozone. Ground-based and satellite instruments have measured decreases in the
amount of stratospheric ozone in our atmosphere. Over some parts of Antarctica, \xp to
60% of the total overhead amount of ozone ^own as the "column ozone') is depleted
during September and Oaober. This phenomenon has come to be known as the Antarctic
'ozone hole." Smaller, but still sigaificant, stratospheric decreases have been seen at other,
more-populated regions of the Earth. Increases in sur6ux UV-B radiauon have been
observed in associaiion with decreases in stratospheric ozone.
The scientific evidence, accumulated over more than two decades of study by the
intemarional research commuoity, has shown that human-made chemicals are responsible
for the observed depletions of the ozone layer over Antarctica and likely play a major role
in ^bal ozone losses. The ozone-deleting compounds contain various combinations of
the chrmical elements chlorine, fluorine, bromine, carbon, and hydrogen, and are often
described by the general term halocttrb&ns. The compounds that contain only carbon,
chlorine, and .fluorine are called chhnfluorocarhons, usually abbreviated as CFO. CFCs,
carbon tetrachloride, and methyl chloroform are important human-made ozone-depleting
gases that have been used in many applications ioduding refrigeration, air conditioning,
foam blowing, cleaning of electronics components, and as solvents. Another important
group of human-made halocarbons is the hdlons, which contain carbon, bromine, fluorine,
and (fa some cases) chlorine, and have been mainly used as fire extinguisbants.
Govemmenu have decided to discontinue production of CFCs, halons, carbon
tetrachloride, and methyl chloroform, and industry has developed more 'ozone-friendly*
substitutes.
Two responses are natural when a new problem has been identified: cure and
prevention. When the problem is the destruction of the stratospheric ozone layer, the
corresponding quesuons are: Can we repair the damage already done? How can we
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82
prevent further desmiction? Remedies have been investigated that could (I) remove CFCs
selectively from our atmosphere, (li) intercept ozone-depledng chlorine before much
depletion has taken place, or (til) replace the ozone lost in the stratosphere (perhaps by
shippii^ the ozone from cities that have too much smog or by malfi'ng new ozone).
Because ozone reacts strongly with other molecules, as noted above, it is too unstable to be
made elsewhere (e.g., in the smog of cities) and transported to the stratosphere. When the
huge volume of the Earth's atmosphere and the magnitude of global stratospheric ozone
depletion are carefully considered, approaches to cures quickly become much too
expensive, impractical, and potentially damaging to the global environment. Prevention
involves the tntemationally agreed-upon Montreal Protocol and its Amendments and
Adjustments, which call for elimination of the production and use of the CFCs and other
ozone-damaging compounds within the next few years. As a rcsuh, the ozone layer is
expected to recover over the next fifty years or so as the atmospheric concentrations of
CFCs and other ozone-depledng compounds slowly decay.
The current understanding of ozone dq>leTion and its relation to humankind is
discussed in detail by the leading scientists in the world's ozone research commxmity in the
ScUm^ Assessment ofOzont Dtple^on: 1994. The answers to the common questions posed
below are based upon that understanding and on the information given in earlier
WMOAJNEP reports.
How Can Chlorofluorocarbons (CFCs) Ge( to the Strazosphere If They're Heavier than Aiii
Although the CFC molecules are indeed several times heavier than air, thousands of
measurements have been made from balloons, aircraft, and satellites demonstrating that the
CFCs are actually present in the stratosphere. The atmosphere is not st^^ant. Winds mix
the atmosphere to altitudes far above the top of the stratosphere much faster than
molecules can settle according to their weight. Gases such as CFCs that are insoluble in
water and relatively tmrcaciive in the lower atmosphere (below about 10 km) are quickly
mJYfd and therefore reach the stratosphere regardless of their weight.
Mtich can be learned about the atmospheric fate of compounds from the measured
dianga in concentration versus altitude. For nrample, the two gases carbon tetrafluoride
(CF^, produced mainly as a by-product of the manufacture of aluminum) and CFC-11
(CCljF, used in a variety of human aoivities) are both much heavier than air. Carbon
tetrafluoride is completely unreactive in the lower 99.9% of the atmosphere, and
measurements show it to be nearly uniformly distributed throughout the atmosphere as
shown in the figure. There hav« also been measurements over the post two detades of
several other completely unreactive gases, one lighter than air (neon) and some heavier than
14
83
air (argon, krypton), which show that they also mix upward uniformly through the
stratosphere reganlless of their weight, just as observed with carbon tetrafiuoride. CFC-11
is unreactive in the lower atmosphere (below about 15 km) and is similarly uniformly
mixed there, as shown. The abundance of CFC-11 decreases as the gas reaches higher
altitudes, where it is broken down by high energy solar ultraviolet radiation. Chlorine
released from this breakdown of CFC-11 and other CFCs remains in the stratosphere for
several years, where it destroys many thousands of molecules of ozone.
Vf'hat is the Evidence that Stratospheric Ozone is Destroyed by Chlorine and Brvminef
Laboratory studies show that chlorine (CI) reacts very n^idly with ozone. They also
show that the reactive chemical chlorine oxide (CIO) formed in that reaaion can undergo
further processes which regenerate the original chlorine, allowing the sequence to be
riq>eated very many times (a "chain reaction"). Similar reactions also take place between
bromine and ozone.
But do these ozone^iestroying reactions occur in the real world? All of our accumulated
scientific experience demonstrates that if the conditions of temperature and pressure arc
like those in the laboratory studies, the same chemical reactions will cake pLce in nature.
However, many other reactions including those of other chemical species are often also
taking place simultaneously in the stratosphere, making the connections among the changes
difiicult to untangle. Nevertheless, whenever chlorine (or bromine) and ozone are found
together in the stratosphere, the ozone-destroying reaaions must be taking place.
Sometimes a small number of chemical reactions is so important in the natural
circumstance that the connections are almost as clear as in laboratory experiments. Such a
sitxiation occurs in the Antarctic stratosphere duuing the springtime fonnation of the ozone
hole. During August and September 19S7 - the end of winter and beginning of spring in
the Southern Hemisphere - aircraft equipped with many different initmments for
measuring a large number of chemical species were flown repeatedly over Antarctica.
Among the chemicals measured were ozone and chlorine onde, the reactive chemical
identiHed in the laboratory as one of the participants in the ozone-destroying chain
reacaons. On the first fi'^^f^ southward imm the southern tip of South America,
relatively high concentrations of ozone were measured cveiywhere over Antarctica. By
mid-September, however, the instruments recorded low conoentratiotu of ozone in regions
where there were high concentrazioiu of chlorine oxide and vice versa, as shown in the
figure. Flights later in Sq>tcmber showed even less ozone over Antarctica, as the chlorine
continued to react with the strato^heric ozone.
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84
Independent measuremenis made by these and other instruments on this and other
airplanes, from the grotind, from balloons, and from satellites have provided a detailed
understanding of the chemical reaaions going on in the Anurcdc stratosphere. Regions
with high concentrations of reactive chlorine reach temperatures so cold (less than
approximately -80*C, or -112*F) that stratospheric clouds form, a rare occurrence except
during the polar winters. These clouds facilirare other chemical reactions that allow the
release of chlorine in sunlight. The chrmical reaaions related to the clouds are now well
iwdeistood through study under laboratory conditions mimirWing those found naturally.
Scientists are working to understand the role of such reactions of chlorine and bromine at
other latitudes, and the involvement of panicles of sulfuric add from volcanoes or other
Does Mou of the 0}UfTint in the Stratosphere Come from Human or Natural Sourcei?
Most of the chlorine in the stratosphere is there as a result of himian activities.
Many compounds containing chlorine arc released at the ground, but those that dissolve
in water cannot reach stratospheric altitudes. Large quantities of chlorine are released from
evaporated ocean spray as sea salt (sodium chloride) aerosol. However, because sea salt
dissolves in water, this chlorine quickly is taken up in clouds or in ice, snow, or rain
droplets and does not reach the stratosphere. Another ground-level source of chlorine is its
use in swimming pools and as household bleach. When released, this chlorine is rapidly
convened to forms that dissolve in water and therefore are removed from the lower
atmosphere, never reaching the stratosphere in significant amounts. Volcanoes can emit
large quantities of hydrogen chloride, but this gas is rapidly converted to hydrochloric acid
in rain water, ice, and snow and does not reach the stratosphere. Even in explosive
volcanic plumes that rise high in the atmosphere, nearly all of the hydrogen chloride is
scrubbed out in predpiution before reachii^ stratospheric altitudes.
In contrast, human-made halocarbons - such as CFCs, carbon tetrachloride (CCLO ^"><^
methyl chloroform (CHjCClj) - are not soluble in water, do not react with snow or other
natural smf^ces, and are not broken down chemically in the lower atmosphere. While the
exhaust firom the Space Shuttle and from some rockets does inject some chlorine directly
into the stratosphere, this input is very small (less than one percent of the annual input
from halocarbons in the present stratosphere, assuming nine Space Shuttle and six Titan TV
rocket launches per year).
Several pieces of evidence combine to esublish human-made halocarbons as the primary
source of stratospheric chlorine. First, measurements have shown that the chlorinated
spedes that rise to the stratosphere are primarily inanufaauicd compounds (mainly CFCs,
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85
carbon tetrachloride, methyl chloroform, aad the HCFC substitutes for CFCs), together
with small amounts of hydrochloric add (HCI) and methyl chloride (CHjCl) which are
partly natural in origin. The natural contribution now is much smaller than that from
human activities, as shown in the figure below. Second, in 1985 and 1992 researchers
measured nearly all known gases containing chlorine in the stratosphere. They found that
human emissions of halocarbons plus the much smaller contribution from natural sources
could accoimt for all of the stratospheric chlorine compounds. Third, the incrozse in total
stratospheric chlorine measured between 1983 and 1992 corresponds with the known
increases in concentrations of hiunan-made halocarbons during that time.
Can Changes in the Sun'i Output Be RespondhUfor the Obtenxd Changes in Ozonef
Stratospheric ozone is primarily created by ultraviolet (UV) light coming from the Sun,
so the Sun's output affects the rate at which ozone is produced. The Sun's energy release
(both as UV lig^t and as charged particles such as elearons and protons) does vary,
especially over the well-known 11-year simspot cycle. Observations over several solar
cycles (since the 1960s) show that total global ozone levels decrease by 1-2% from the
inaTimiifn to the minimum of a typical cycle. Changes in the Sun's output cannot be
responsible for the observed long-term changes in ozone, because these downward trends
art much larger than 1-2%. Further, during the period since 1979, the Sun's energy output
has gone from a maximum to a minimum in 1985 and back through another maximum in
1991, but the trend in ozone was downward throughout that time. The ozone trends
presented in this and previous international scientific assessments have been obtained by
evaluating the long-term changes in ozone conoentrarions after accounting for the solar
infliifnf»»
. When Did the Antarctic Ozone Hole Firjt Appearf
The Antarctic ozone hole is a new phenomenon. The figure shows that observed
ozone over the British Antarctic Survey station at Halley Bay, Antarctica first revealed
obvious decreases in the early 1980$ compared to dau obtained sinoe 1957. The ozone hole
is formed each year when tfaeze is a sharp decline (currently up to 60%) in the total ozone
over most of Antarctica for a period of aboixt two months during Southern Hemisphere
^ring (September and October). Observations from thne other stations in Antarctica,
also covering several decades, reveal similar progressive, recent decreases in springtime
ozone. The ozone hole has been shown to resuh from destruction of stratospheric ozone
by gases nontatntog chlorine and bromine, whose sources are mainly human-made
halocarbon gases.
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86
Before the stratosphere was aiicatd by hunun-made chlorine and bromine, the
naturally occurring springtime ozone levels over Antarctica wax about 30-40% lower than
springtime ozone levels over the Arctic This natural difference between Antaraic and
Arctic conditions was first observed in the late 1950s by Dobson. It stems £rom the
exceptionally cold temperatures and different winter wind patterns within the Antarctic
stratosphere as compared to the Arctic This is not at all the same phenomenon as the
marked downward trend in total ozone in recent years referred to as the ozone hole.
Changes in stratospheric meteorology cannot explain the ozone hole. Measurements
show that wintertime Antaraic stratospheric temperatures of past decades have not
changed prior to the development of the hole each September. Groimd, aircraft, and
lafrllirc measurements have provided, in contrast, clear evidence of the importance of the
chemistry of chlorine and bromine originating from humanrmade compounds in depleting
Antarctic ozone in recent years.
A single report of extremely low Antarctic winter ozone in one location in 1958 by an
unproven technique has been shown to be completely inconsistent with the measurements
depicted here and with all credible measurements of total ozone.
Vfiy is the Ozone Hole Observed over Antarctica When CFCs Are Released Mainly in the
Northern Hemispheref
Human emissions of CFCs do occur mainly in the Northern Hemisphere, with about
90% released in the latitudes corresponding to Europe, Russia, Japan, and North America.
Gases such as CFCs that arc insoluble in water and relatively unreactive are mixed within a
year or two throughout the lower atmosphere (below about 10 km). The CFCs in this
well-mixed air rise from the lower atmosphere into the stratosphere mainly in tropical
latitudes. Winds then move this air poleward - both north and south - from the tropics,
so that air throu^iout the stratosphere contains nearly the same amount of chlorine.
However, the meteorologies of the two polar regions are very different from each other
because of major differcnors at the Earth's sur^ce. The South Pole is part of a very large
land mass (Antarctica) that is completely surrounded by ocean. These conditions produce
very low stratoapheric temperanues which in turn lead to formation of clouds (polar
stiatospheric clouds). The clouds that form at low tenq>enRure3 lead to chemical changes
that promote r^id ozone loss during September and October of each year, resulting in the
ozone hole.
In contrast, the Earth's vatiaoe in the northern polar reg;ion lacks the land/ocean
symmetry characteristic of the southern polar area. As a consequence, Arctic stratospheric
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87
air 15 generally much wanner tiun in tbe Antarciic, and fewer clouds form there.
Tiierefore, the ozone depletion in the Araic is much less than in the Antarctic
Is the Depletion of the Ozone Layer Leading to an Increase in Ground-Level Ultraviolet
Radiationf
The Sun emits light over a wide range of energies, with about two f>eroent given off in
the form of high-energy, ultraviolet (UV) radiation. Some of this UV radiation (UV-B) is
especially effective in causing damage to living things, including sunburn, «lct'n cancer, and
eye damage for humans. The amount of solar UV radiation received at any particular
location on the Earth's surface d^>ends upon the position of the Stm above the horizon, on
the amount of ozone in the atmosphere, and upon local cloudiness and pollution.
Scientists agree that in the absence of changes in clouds or poUuzion, decreases in
atmospheric ozone will increase ground-level UV radiation.
The largest decreases in ozone during the last decade have been observed over
Antarctica, especially during each September and October when the "ozone hole" forms.
During the last several years, simultaneous measurements of UV radiation and total ozone
have been made at several Antarctic sutions. Vhen the ozone amounts decrease, UV-B
increases. Because of the ozone hole, the UV-B intensity at Palmer Station, Antarctica, in
late October, 1993, was more intense than found at San Diego, California, at any time
daring all of 1993.
In areas where small ozone depletion has been observed, UV-B increases are more
difScult to detect. Detection of UV trends associated with ozone decreases can also be
complicated by changes in cloudiness or by local pollution, as well as by difficulties in
keeping the detection instriunent in precisely the same condition over many years. Prior
to the late 1980s, instruments with the necessary accuracy and stability for measurement of
small long-term trends in grotind-level UV-B were not employed. Recently, however, such
instruments have been used in the Antarctic because of the very large changes in ozone
being observed there. When high-quality measurements have been nude in other areas far
from major cities and their associated air pollution, decreases in ozone have regularly been
acconq>anled by increases in UV-B. The dau from urban locations with older, less
specialized instruments provide much less reliable information, especially because good
simultaneous measurements are not available for any changes in cloudiness or local
pollution.
How Severe Is the Ozone Depletion Now, and h It Expected to Get Worse?
19
88
SdentiGc evidence shows chat ozone depletion catued by human-made chemicals is
continuing and is expected to persist until chlorine and bromine levels are reduced.
Worldwide monitortag has shown that stratospheric ozone has been decreasing for the past
two decades or more. Globally averaged loses have totaled about 5% since the mid-1960s,
with cumulative losses of about 10% in the winter and spring and 5% in the summer and
autumn over locations such as Europe, North America, and Australia. Since the laie-1970s,
an ozone "hole" has formed in Antarctica each Southern Hemisphere spring (September /
October), in which up to 60% of the total ozone is depleted. The large increase in
atmospheric concentrations of human-made chlorine and bromine compounds is
responsible for the formation of the Antarctic ozone hole, and the weight of evidence
indicates that it also plays a major role in midlatitude ozone depletion.
During 1992 and 1993 ozone in many locations dropped to record low values:
springtime depletions exceeded 20% in some populated northern midlatitude regions, and
the levels in the Antarctic ozone hole fell to the lowest values ever recorded. The
unusually large ozone decreases of 1992 and 1993 arc believed to be related, in part, to the
volcanic eruption of Mount Pinatubo in the Philippines during 1991. This eruption
produced large amounts of stratospheric sulfate aerosols that temporarily increased the
ozone depletion caused by human-made chlorine and bromine compounds. Recent
observations have shown that as those aerosols have been swept out of the stratosphere,
ozone concentrations have returned to the depicted levels consistent with the downward
trend observed before the Mount Pinatubo eruption.
In 1987 the recognition of the potential for chlorine and bromine to destroy
stratospheric ozone led to an international agreement flhe United Nations Montreal
Protocol on Substances thai Deplete the Ozone Layer) to reduce the global production of
o20ne-depleting substances. Since then, new global observations of significant ozone
depletion have prompted amendments to strengthen the treaty. The 1992 Copenhagen
Amendments call for a ban on production of the most damaging compoimds by 1996. The
assessment report shows past and projected future stratospheric abundances of chlorine and
bromine: (a) without the Protocol; (b) under the Protocol's original provisions; and (c)
tmder the Copenhagen Amendments now in force. Without the Montreal Protocol and its
Amendments, continuing human use of CFCs and other compotmds would have tripled
the straospheric abundances of chlorine and bromine by aboiu the year 2050. Ciirrent
scientific understanding indicates that such increases would have led to ^obal ozone
deletion very much larger than observed today. In contrast, under current international
agreements, which are now reducing and will eventually eh'minate human emissions of
ozone-depleting gases, the stratospheric abundances of chlorine and bromine are expected to
reach their maximum within a few years and then slowly decline. All other things being
20
89
equal, the ozone layer is expected to return to normal by the middle of the next century.
In summary, record low ozone levels have been observed in recent yean, and
substantially larger future global depletions in ozone would have been highly likely
without reductions in human emissions of ozone-depleting gases. However, worldwide
compliance with current international agreements is rapidly reducing the yearly emissions
of these compounds. As these emissions cease, the ozone layer will gradually improve over
the next sevoal decades. The recovery of the ozone layer will be gradual because of the
long times reqtured for CFCs to be removed from the atmosphere.
21
90
World Meteorological Organization
Global Ozone Research and Monitoring Project — Report No. 37
SciENTiHC Assessment of
Ozone Depletion: 1994
Executive Summary
National Oceanic and Atmospheric Administration
National Aeronautics and Space Administration
United Nations Environment Programme
World Meteorological Organization
91
Preface
The present document contains key summaiies from the Scientific Assessment of Ozone Depletion: 1994. The full
assessment report will be part of the information upon which the Parties to the United Nations Montreal Protocol will
base their future decisions regarding protection of the stratospheric ozone layer
Specifically, the Montreal Protocol on Substances That Deplete the Ozone Layer states (Article 6): ". . . the Parties
shall assess the control measures ... on the basis of available scientific, environmental, technical, and economic infor-
mation." To provide the mechanisms whereby these assessments are conducted, the Protocol further states: ". . . the
Parties shall convene appropriate panels of experts" and "the panels will report their conclusions ... to the Parties."
Three assessment reports have been prepared during 1994 to be available to the Parties in advance of their meeting
in 1995, at which they will consider the need to amend or adjust the Protocol. The two compatuon reports to the
scientific assessment focus on the environmental and health effects of ozone layer depletion and on the technology and
economic implications of mitigation approaches.
The scientific assessment summarized in the present document is the latest in a series of seven scientific reports
prepared by the world's leading experts in the atmospheric sciences and under the international auspices of the World
Meteorological Organization (WMO) and the United Nations Environment Programme (UNEP). The chronology of
those scientific assessments and the relation to the international policy process are sununarized as follows:
Scientific Assessment
The Stratosphere 1981 Theory and Measurements.
WMO No. 11.
Atmospheric Ozone 1985. 3 vol. WMO No. 16.
International Ozone Trends Panel Report 1988.
2 vol. WMO No. 18.
1989 Scientific Assessment of Stratospheric Ozone:
1989. 2 vol. WMO No. 20.
1990 London Amendment
1991 Scientific Assessment of Ozone Depletion: 1991.
WMO No. 25.
1992 Methyl Bromide: Its Atmospheric Science, Technology, and
Economics (Assessment Supplement). UNEP (1992).
1992 Copenhagen Amendment
1994 Scientific Assessment of Ozone Depletion: 1994.
Year
Policy Process
1981
1985
Vienna Convention
1987
Montreal Protocol
1988
WMO No. 37.
( 1 995) Vienna Amendment (?)
The genesis o( Scientific Assessment of Ozone Depletion: 1994 occurred at the 4th meeting of the Conference of the
Parties to the Montreal Protocol in Copenhagen, Denmark, in November 1992, at which the scope of the scientific needs
of the Parties was defined. The formal planning of the prese.nt report was a workshop that was held on 1 1 June 1993 in
92
Virginia Beach, Virginia, at which an international steering group crafted the outline and suggested scientists from the
world community to serve as authors. The first drafts of the chapters were examined at a meeting that occurred on 2 - 4
March 1994 in Washington, D.C., at which the authors and a small number of international experts improved the coor-
dination of the text of the chapters.
The second draft was sent out to 1 23 scientists worldwide for a mail peer review. These anonymous comments
were considered by the authors. At a Panel Review Meeting in Les Diablerets, Switzerland, held on 18-21 July 1994,
the responses to these mail review comments were proposed by the authors and discussed by the 80 participants. Final
. changes to the chapters were decided upon, and the Executive Summary contained herein was prepared by the partici-
pants.
The group also focused on a set of questions commonly asked about the ozone layer Based upon the scientific
understanding represented by the assessments, answers to these common questions were prepared and are also included
here.
As the accompanying list indicates, the Scientific Assessment of Ozone Depletion: 1994 is the product of 295
scientists from the developed and developing world' who contributed to its preparation and review (230 scientists
prepared the report and 147 scientists participated in the peer review process).
What follows is a summary of their current understanding of the stratospheric ozone layer and its relation to hu-
mankind.
' Participating were Argentina. Australia, Austria, Belgium, Brazil, Canada, Chile, Cuba, Czech Republic, l>enmarlc. Egypt. France, Geimaiiy,
Greece, Hungary, India, Iran, Ireland. Israel, Italy, Japan, Kenya, Malaysia, New Zealand, Norway, Poland. Russia, South Africa, Sweden. Switzer-
land. Taiwan. The Netherlands. The People's Republic of China. United Kingdom, United Stales of America, and Venezuela.
Executive Summary
Recent Major Scientific Findings and Observations
The laboratory investigations, atmospheric observations, and theoretical and modeling smdies of the past few years
have provided a deeper understanding of the human-influenced and natural chemical changes in the atmosphere and
their relation to the Earth's stratospheric ozone layer and radiative balance of the climate system. Since the last interna-
tional scientific assessment of the state of understanding, there have been several key ozone-related findings,
observations, and conclusions:
The atmospheric growth rates of several major ozone-depleting substances have slowed, demonstrating the
expected impact of the Montreal Protocol and its Amendments and Adjustments. The abundances of the
chlorofluorocarbons (CFCs), carbon tetrachloride, methyl chloroform, and halons in the atmosphere have been
monitored at global ground-based sites since about 1978. Over much of that period, the annual growth rates of
these gases have been positive. However, the data of recent years clearly show that the growth rates of CFC- 1 1,
CFC-12, halon-1301, and halon-121 1 are slowing down. In psirticular, total tropospheric organic chlorine in-
creased by only about 60 ppt/year (1.6%) in 1992, compared to 1 10 ppt/year (2.9%) in 1989. Furthermore,
tropospheric bromine in halons increased by only about 0.25 ppt/year in 1992, compared to about 0.85 ppt/year in
1989. The abundance of carbon tetrachloride is actually decreasing. The observed trends in total tropospheric
organic chlorine are consistent with reported production data, suggesting less emission than the maximum al-
lowed under the Montreal Protocol and its Amendments and Adjustments. Peak total chlorine/bromine loading in
the troposphere is expected to occur in 1994, but the stratospheric peak will lag by about 3 - 5 years. Since the
stratospheric abundances of chlorine and bromine are expected to continue to grow for a few more years, increas-
ing global ozone losses are predicted (other things being equal) for the remainder of the decade, with gradual
recovery in the 21st century.
• The atmospheric abundances of several of the CFC substitutes are increasing, as anticipated. With phase-
out dates for the CFCs and other ozone-depleting substances now fixed by international agreements, several
hydrochlorofluorocarbons (HCFCs) and hydrofluorocarbons (HFCs) are being manufactured and used as substi-
tutes. The atmospheric growth of some of these compounds (.e.g., HCFC-22) has been observed for several years,
and the growth rates of others (e.g., HCFC-142b and HCFC-14lb) are now being monitored. Tropospheric
chlorine in HCFCs increased by 5 ppt/year in 1989 and about 10 ppt/year in 1992.
• Record low global ozone levels were measured over the past two years. Anomalous ozone decreases were
observed in the midlatitudes of both hemispheres in 1992 and 1993. The Northern Hemispheric decreases were
larger than those in the Southern Hemisphere. Globally, ozone values were I - 2% lower than would be expected
from an e..trapolation of the trend prior to 1991, allowing for solar-cycle and quasi-biennial-oscillation (QBO)
effects. The 1994 global ozone levels are returning to values closer to those expected from the longer-term
downward trend.
94
The stratosphere was perturbed by a major volcanic eruption. The eruption of Mt. Pinatubo in 1991 led to a
large increase in sulfate aerosol in the lower stratosphere throughout the globe. Reactions on sulfate aerosols
resulted in significant, but temporary, changes in the chemical partitioning that accelerated the photochemical
ozone loss associated with reactive hydrogen (HOx), chlorine, and bromine compounds in the lower stratosphere
in midlatimdes and polar regions. Absorption of terrestrial and solar radiation by the Mt. Pinatubo aerosol result-
ed in a transitory rise of 1°C (globally averaged) in the lower-stratospheric temperature and also affected the
distribution of ozone through circulation changes. The observed 1994 recovery of global ozone is qualitatively
consistent with observed gradual reductions of the abundances of these volcanic particles in the stratosphere.
Downward trends in total-column ozone continue to be observed over much of the globe, but their magni-
tudes are underestimated by numerical models. Decreases in ozone abundances of about 4-5% per decade at
midlatitudes in the Northern and Southern Hemispheres continue to be observed by both ground-based and satel-
lite-borne monitoring instruments. At midlatitudes, the losses continue to be much larger during winter/spring
than during summer/fall in both hemispheres, and the depletion increases with latitude, particularly in the South-
era Hemisphere. Little or no downward trends are observed in the tropics (20°N - 20°S). While the current two-
dimensional stratospheric models simulate the observed trends quite well during some seasons and latitudes, they
underestimate the trends by factors of up to three in winter/spring at mid- and high latitudes. Several known
atmospheric processes that involve chlorine and bromine and that affect ozone in the lower stratosphere are
difficult to model and have not been adequately incorporated into these models.
Observations have demonstrated that halogen chemistry plays a larger role in the chemical destruction of
ozone in the midlatitude lower stratosphere than expected from gas phase chemistry. Direct in situ measure-
ments of radical species in the lower stratosphere, coupled with model calculations, have quantitatively shown
that the in situ photochemical loss of ozone due to (largely natiual) reactive nitrogen (NO,) compounds is smaller
than that predicted from gas phase chemistry, while that due to (largely namral) HO, compounds and (largely
anthropogenic) chlorine and bromine compounds is larger than that predicted from gas phase chemistry. This
confirms the key role of chemical reactions on sulfate aerosols in controlling the chemical balance of the lower
stratosphere. These and other recent scientific findings strengthen the conclusion of the previous assessment that
the weight of scientific evidence suggests that the observed middle- and high-latitude ozone losses are lai;gely due
to anthropogenic chlorine and bromine compounds.
The conclusion that anthropogenic chlorine and bromine compounds, coupled with surface chemistry on
natural polar stratospheric particles, are the cause of polar ozone depletion has been further strengthened.
Laboratory studies have provided a greatly improved understanding of how the chemistry on the surfaces of ice.
nitrate, and sulfate particles can increase the abundance of ozone-depleting forms of chlorine in the polar strato-
spheres. Furthermore, satellite and in situ observations of the abundances of reactive nitrogen and chlorine
compounds have improved the explanation of the different ozone-altering properties of the Antarctic and Arctic.
The Antarctic ozone "holes" of 1992 and 1993 were the most severe on record. The Antarctic ozone "hole"
has continued to occur seasonally every year since its advent in the late- 1970s, with the occurrences over the last
several years being particularly pronounced. Satellite, balloon-borne, and ground-based monitoring instrurttents
revealed that the Antarctic ozone "holes" of 1992 and 1993 were the biggest (areal extent) and deepest (minimum
amounts of ozone overhead), with ozone being locally depleted by more than 99% between about 14 - 19 km in
October, 1992 and 1993. It is likely that these larger-than-usual ozone depletions could be attributed, at least in
part, to sulfate aerosols from Mt. Pinatubo increasing the effectiveness of chlorine- and bromine-catalyzed ozone
destruction. A substantial Antarctic ozone "hole" is expected to occur each austral spring for many more decades
because stratospheric chlorine and bromine abundances will approach the pre-Antarctic-ozone-"hole" levels
flate- 1970s) very slowly during the next century.
S
95
Ozone losses have been detected in the Arctic winter stratosphere, and their links to halogen chemistry
have been established. Studies in the Arctic lower stratosphere have been expanded to include more widespread
observations of ozone and key reactive species. In the late-winter/early-spring period, additional chemical losses
of ozone up to 15 - 20% at some altitudes are deduced from these observations, particularly in the winters of 1991/
2 and 1992/3. Model calculations constrained by the observations are also consistent with these losses, increasing
the confldence in the role of chlorine and bromine in ozone destruction. The interannual variability in the photo-
chemical and dynamical conditions of the Arctic polar vortex continues to limit the ability to predict ozone
changes in future years.
The linl( lietween a decrease in stratospheric ozone and an increase in surface ultraviolet (UV) radiation
lias been further strengthened. Measurements of UV radiation at the surface under clear-sky conditions show
that low overhead ozone yields high UV radiation and in the amount predicted by radiative-transfer theory. Large
increases of surface UV are observed in Antarctica and the southern part of South America during the period of
the seasonal ozone "hole." Furthermore, elevated surface UV levels at mid-to-high latitudes were observed in the
Northern Hemisphere in 1992 and 1993, corresponding to the low ozone levels of those years. However, the lack
of a decadal (or longer) record of accurate monitoring of surface U V levels and the variation introduced by clouds
and other factors have precluded the unequivocal identification of a long-term trend in surface UV radiation.
Methyl bromide continues to be viewed as a significant ozonenlepleting compound. Increased attention has
been focused upon the ozone-depleting role of methyl bromide. Three potentially major anthropogenic sources of
atmospheric methyl bromide have been identified (soil fumigation, biomass burning, and the exhaust of automo-
biles using leaded gasoline), in addition to the natural oceanic source. Recent laboratory studies have confirmed
the fast rate for the BrO -t- HO2 reaction and established a negUgible reaction pathway producing HBr, both of
which imply greater ozone losses due to emissions of compounds containing bromine. While the magnitude of
the atmospheric photochemical removal is well understood, there are significant uncertainties in quantifying the
oceanic sink for atmospheric methyl bromide. The best estimate for the overall lifetime of atmospheric methyl
bromide is 1 .3 years, with a range of 0.8 - 1 .7 years. The Ozone Depletion Potential (ODP) for methyl bromide is
calculated to be about 0.6 (relative to an ODP of I for CFC- II).
Stratospheric ozone losses cause a global-mean negative radiative forcing. In the 1991 scientific assessment,
it was pointed out that the global ozone losses that were occurring in the lower stratosphere caused this region to
cool and result in less radiation reaching the surface-troposphere system. Recent model studies have strengthened
this picture. A long-term global-mean cooling of the lower stratosphere of between 0.25 and 0.4°Cydecade has
been observed over the last three decades. Calculations indicate that, on a global mean, the ozone losses between
1980 and 1990 offset about 20% of the radiative forcing due to the well-mixed greenhouse-gas increases during
that period (i.e., carbon dioxide, methane, nitrous oxide, and halocarbons).
TTopospheric ozone, which is a greenhouse gas, appears to have increased in many regions of the Northern
Hemisphere. Observations show that tropospheric ozone, which is formed by chemical reactions involving
pollutants, has increased above many locations in the Northern Hemisphere over the last 30 years. However, in
the 1980s, the trends were variable, being small or nonexistent. In the Southern Hemisphere, there are insufficient
data to draw strong inferences. At the South Pole, a decrease has been observed since the mid-1980s. Model
simulations and limited observations suggest that tropospheric ozone has increased in the Northern Hemisphere
since pre-industrial times. Such changes would augment the radiative forcing from all other greenhouse gases by
about 20% over the same time period.
96
•' The atmospheric residence times of the important ozone-depleting gases, CFC-11 and methyl chloroform,
and the greenhouse gas, methane, are now better known. A reconciliation of observed concentrations with
known emissions using an atmospheric model has led to a best-estimate lifetime of 50 years for CFC- 1 1 and 5.4
years for methyl chloroform, with uncertainties of about 10%. These lifetimes provide an accurate standard for
gases destroyed only in the stratosphere (such as CFCs and nitrous oxide) and for those also reacting with tropo-
spheric hydroxyl radical, OH (such as HCFCs and HFCs), respectively. Recent model simulations of methane
perturbations and a theoretical analysis of the tropospheric chemical system that couples methane, carbon monox-
ide, and OH have demonstrated that methane perturbations decay with a lengthened time scale in a range of about
12-17 years, as compared with the 10- year lifetime derived from the total abundance and losses. This longer
response time and other indirect effects increase the estimate of the effectiveness of emissions of methane as a
greenhouse gas by a factor of about two compared to the direct-effect-only values given in the 1 99 1 assessment.
Supporting Scientific Evidence and Related Issues
Ozone Chances in the Tropics and MiDiATrruDES and Their Interpretation
• Analysis of global total-column ozone data through early 1994 shows substantial decreases of ozone in all sea-
sons at midlatitudes (30° - 60°) of both hemispheres. For example, in the middle latitudes of the Northern
Hemisphere, downward trends of about 6% per decade over 1979 - 1994 were observed in winter and spring and
about 3% per decade were observed in summer and fall. In the Southern Hemisphere, the seasonal difference was
somewhat less, but the midlatitude trends averaged a similar 4% to 5% per decade. There are no statistically
significant trends in the tropics (20°S - 20°N). Trends through 1994 are about 1 % per decade more negative in the
Northern Hemisphere (2% per decade in the midlatitude winter/spring in the Northem Hemisphere) compared to
those calculated without using data after May 1991. At Northem midlatitudes, the downward trend in ozone
between 198 1-1991 was about 2% per decade greater compared to that of the period 1970 - 1980.
• Satellite and ozonesonde data show that much of the downward trend in ozone occurs below 25 km {i.e., in the
lower stratosphere). For the region 20 - 25 km, there is good agreement between the trends firom the Stratospheric
Aerosol and Gas Experiment (SAGE I/II) satellite instrument data and those from ozonesondes, with an observed
annual-average decrease of 7 ± 4% per decade from 1979 to 1991 at 30° - 50°N latitude. Below 20 km, SAGE
yields negative trends as large as 20 ± 8% per decade at 1 6 - 17 km, while the average of available midlatitude
ozonesonde data shows smaller negative trends of 7 ± 3% per decade. Integration of the ozonesonde data yields
total-ozone trends consistent with total-ozone measurements. In the 1980s, upper-stratospheric (35 - 45 km)
ozone trends determined by the data from SAGE I/II, Solar Backscatter Ultraviolet satellite spectrometer
(SBUV), and the Umkehr method agree well at midlatitudes, but less so in the tropics. Ozone declined 5 - 10%
per decade at 35 - 45 km between 30°- SO°N and slightly more at southern midlatitudes. In the tropics at 45 km,
SAGE I/Il and SBUV yield downward trends of 10 and 5% per decade, respectively.
• Simultaneous in situ measurements of a suite of reactive chemical species have directly confirmed modeUng
studies implying that the chemical destruction of ozone in the midlatitude lower stratosphere is more strongly
influenced by HO, and halogen chemistry than NO, chemistry. The seasonal cycle of CIO in the lower strato-
sphere at midlatitudes in both hemispheres supports a role for in situ heterogeneous perturbations {i.e., on sulfate
aerosols),^ but does not appear consistent with the timing of vortex processing or dilution. These studies provide
key svip)>(^rt for the view that sulfate aerosol chemistiy plays an important role in detennining midlatitude chem-
ical ozone destruction rates.
97
The model-calculated ozone depletions in the upper stratosphere for 1980 - 1990 are in broad agreement with the
measurements. Although these model-calculated ozone depletions did not consider radiative feedbacks and tem-
perature trends, including these effects is not likely to reduce the predicted ozone changes by more than 20%.
Models including the chemistry involving sulfate aerosols and polar stratospheric clouds (PSCs) better simulate
the observed total ozone depletions of the past decade than models that include only gas phase reactions. How-
ever, they still underestimate the ozone loss by factors ranging from 1.3 to 3.0.
Some unresolved discrepancies between observations and models exist for the partitioning of inoi;ganic chlorine
species, which could impact model predictions of ozone trends. These occur for the CIO/HCI ratio in the upper
stratosphere and the fraction of HCl to total inorganic chlorine in the lower stratosphere.
The transport of ozone-depleted air from polar regions has the potential to influence ozone concentrations at
middle latitudes. While there are uncertainties about the importance of this process relative to in situ chemistry
for midlatitude ozone loss, both directly involve ozone destruction by chlorine- and bromine-catalyzed reactions.
Radiosonde and satellite data continue to show a long-term cooling trend in globally annual-average lower-strato-
spheric temperatures of about 0.3 - 0.4°C per decade over the last three decades. Models suggest that ozone
depletion is the major contributor to this trend.
Anomalously large downward ozone trends have been observed in midlatitudes of both hemispheres in 1992 and
1993 (i.e.. the first two years after the eruption of Mt. Pinatubo), with Northern-Hemispheric decreases larger than
those of the Southern Hemisphere. Global-average total-ozone levels in early 1993 were about 1% to 2% below
that expected from the long-term trend and the particular phase of the solar and QBO cycles, while peak decreases
of about 6 - 8% from expected ozone levels were seen over 45 - 60°N. In the first half of 1994, ozone levels
returned to values closer to those expected from the long-term trend.
The sulfur gases injected by Mt. Pinatubo led to large enhancements in stratospheric sulfate aerosol surface areas
(by a maximum factor of about 30 - 40 at northern midlatitudes within a year after the eruption), which have
subsequently declined.
Anomalously low ozone was measured at altitudes below 25 km at a Northern-Hemispheric midlatitude station in
1992 and 1993 and was correlated with observed enhancements in sulfate-aerosol surface areas, pointing towards
a causal link.
Observations indicate that the eruption of Mt. Pinatubo did not significantly increase the HCl content of the
stratosphere.
The recent large ozone changes at midlatitudes are highly likely to have been due, at least in part, to the greatly
increased sulfate aerosol in the lower stratosphere following Mt. Pinatubo. Observations and laboratory studies
have demonstrated the importance of heterogeneous hydrolysis of N2O5 on sulfate aerosols in the atmosphere.
Evidence suggests that CIONO2 hydrolysis also occurs on sulfate aerosols under cold conditions. Both processes
perturb the chemistry in such a way as to increase ozone loss through coupling with the anthropogenic chlorine
and bromine loading of the stratosphere.
• Global mean lower stratospheric temperatures showed a marked transitory rise of about I °C following the erup-
tion of Mt. Pinatubo in 1991, consistent with model calculations. The warming is likely due to absorption of
radiation by the aerosols.
Polar Ozone Depletion
• In 1992 and 1993, the biggest-ever (areal extent) and deepest-ever (minimum ozone below 100 Dobson units)
ozone "holes" were observed in the Antarctic. These extreme ozone depletions may have been due to the chem-
ical perturbations caused by sulfate aerosols from Mt. Pinatubo, acting in addition to the well-recognized chlorine
and bromine reactions on polar stratospheric clouds.
• Recent results of observational and modeling studies reaffirm the role of anthropogenic halocaibon species in
Antarctic ozone depletion. Satellite observations show a strong spatial and temporal correlation of CIO abun-
dances with ozone depletion in the Antarctic vortex. In the Arctic winter, a much smaller ozone loss has been
observed. These losses are both consistent with photochemical model calculations constrained with observations
from in situ and satellite instruments.
• Extensive new measurements of HCl, CIO, and CIONO2 from satellites and in situ techniques have confirmed the
picture of the chemical processes responsible for chlorine activation in polar regions and the recovery from those
processes, strengthening current understanding of the seasonal cycle of ozone depletion in both polar regions.
• New laboratory and field studies strengthen the confidence that reactions on sulfate aerosols can activate chlorine
under cold conditions, particularly those in the polar regions. Under volcanically perturbed conditions when
aerosols are enhanced, these processes also likely contribute to ozone losses at the edges of PSC formation
regions (both vertical and horizontal) just outside of the southern vortex and in the Arctic.
• Satellite measurements have confirmed that the Arctic vortex is much less denitrified than the Antarctic, which is
likely to be an important factor in detemuning the interhemispheric differences in polar ozone loss.
• Interannual variability in the photochemical and dynamical conditions of the vortices limits reliable predictions of
fiiture ozone changes in the polar regions, particularly in the Arctic.
Coupling Between Polar Regions and MmLATrruDES
• Recent satellite observations of long-lived tracers and modeling studies confirm that, above 16 km. air near the
center of the polar vortex is substantially isolated from lower latitudes, especially in the Antarctic.
• Erosion of the vortex by planetary-wave activity transports air from the vortex -edge region to lower latitudes.
Nearly alt observational and modeling studies are consistent with a time scale of 3 - 4 months to replace a substan-
tial fraction of Antarctic vortex air. The importance of this transport to in situ chemical effects for midlatitude
ozone loss remains poorly known.
• Air is readily transported between polar regions and midlatitudes below 1 6 km. The influence of this transport on
midlatitude ozone loss has not been quantified.
12
99
Tropospheric Ozone
• There is observational evidence that tropospheric ozone (about 10% of the total-column ozone) has increased in
the Northern Hemisphere (north of 20°N) over the past three decades. The upward trends are highly regional.
They are smaller in the 1980s than in the 1970s and may be slightly negative at some locations. European
measurements at surface sites also indicate a doubling in the lower-tropospheric ozone concentrations since ear-
lier this century. At the South Pole, a decrease has been observed since the mid- 1980s. Elsewhere in the Southern
Hemisphere, there are insufficient data to draw strong inferences.
• There is strong evidence that ozone levels in the boundary layer over the populated regions of the Northern
Hemisphere are enhanced by more than 50% due to photochemical production from anthropogenic precursors,
and that export of ozone from North America is a significant source for the North Atlantic region during summer.
It has also been shown that biomass burning is a significant source of ozone (and carbon monoxide) in the tropics
during the dry season.
• An increase in UV-B radiation (e.g., from stratospheric ozone loss) is expected to decrease tropospheric ozone in
the background atmosphere, but, in some cases, it will increase production of ozone in the more polluted regions.
• Model calculations predict that a 20% increase in methane concentrations would result in tropospheric ozone
increases ranging from 0.5 to 2.5 ppb in the tropics and the northern midlatitude summer, and an increase in the
methane residence time to about 14 years (a range of 12 - 17 years). Although there is a high degree of consis-
tency in the global transport of short-lived tracers within three-dimensional chemical-transport models, and a
general agreement in the computation of photochemical rates affecting tropospheric ozone, many processes con-
trolling tropospheric ozone are not adequately represented or tested in the models, hence limiting the accuracy of
these results.
Tremds in Source Gases Relatinc to Ozone Changes
• CFCs, carbon tetrachloride, methyl chloroform, and the halons are major anthropogenic source gases for strato-
spheric chlorine and bromine, and hence stratospheric ozone destruction. Observations from several monitoring
networks wortdwide have demonstrated slowdowns in growth rates of these species that are consistent (except for
carbon tetrachloride) with expectations based upon recent decreases in emissions. In addition, observations from
several sites have revealed accelerating growth rates of the CFC substitutes, HCFC-22, HCFC- 141b, and HCFC-
142b, as expected from their increasing use.
• Methane levels in the atmosphere affect tropospheric and stratospheric ozone levels. Global methane increased
by 7% over about the past decade. However, the 1980s were characterized by slower growth rates, dropping from
approximately 20 ppb per year in 1980 to about 10 ppb per year by the end of the decade. Methane growth rates
slowed dramatically in 1991 and 1992, but the very recent data suggest that they have started to increase in late
1993. The cause(s) of this behavior are not known, but it is probably due to changes in methane sources rather
than sinks.
• Despite the increased methane levels, the total amount of carbon monoxide in today's atmosphere is less than it
was a decade ago. Recent analyses of global caitran monoxide data show that tropospheric levels grew from the
early 1980s toabout 1987 and have declined from the late 1980s to the present. Thecause(s) of this behavior have
not been identified.
13
100
Consequences of Ozone Changes
• The only general circulation model (GCM) simulation to investigate the climatic impacts of observed ozone
depletions between 1970 and 1990 supports earlier suggestions that these depletions reduced the model-predicted
wanning due to well-mixed greenhouse gases by about 20%. This is consistent with radiative forcing calcula-
tions.
• Model simulations suggest that increases in tropospheric ozone since pre-industrial times may have made signif-
icant contributions to the greenhouse forcing of the Earth's climate system, enhancing the current total forcing by
about 20% compared to that arising from the changes in the well-mixed greenhouses gases over that period.
• Large increases in ultraviolet (UV) radiation have been observed in association with the ozone hole at high south-
em latitudes. The measured UV erUiancements agree well with model calculations.
• Clear-sky UV measurements at midlatitude locations in the Southern Hemisphere are significantly larger than at
a corresponding site in the Northern Hemisphere, in agreement with expected differences due to ozone column
and Sun-Earth separation.
• Local increases in UV-B were measured in 1992/93 at mid- and high latitudes in the Northern Hemisphere. The
spectral signatures of the enhancements clearly implicate the anomalously low ozone observed in those years,
rather than variability of cloud cover or tropospheric pollution. Such correlations add confidence to the ability to
link ozone changes to UV-B changes over relatively long time scales.
• Increases in clear-sky UV over the period 1979 to 1993 due to observed ozone changes are calculated to be
greatest at short wavelengths and at high latitudes. Poleward of 45°, the increases are greatest in the Southern
Hemisphere.
• Uncertainties in calibration, influence of tropospheric pollution, and difficulties of interpreting data from broad-
band instruments continue to preclude the unequivocal identification of long-term UV trends. However, data
from two relatively unpolluted sites do appear to show UV increases consistent with observed ozone trends.
Given the uncertainties of these studies, it now appears that quantification of the natural (i.e., pre-ozone-reduc-
tion) UV basehne has been irrevocably lost at mid- and high latitudes.
• Scattering of UV radiation by stratospheric aerosols from the Ml Pinatubo eruption did not alter total surface-UV
levels appreciably.
Related Phenomena and Issues
Methyl Bromide
• Three potentially major anthropogenic sourx:es of methyl bromide have been identified: (i) soil fumigation: 20 to
60 ktons per year, where new measurements reaflinn that about 50% (ranging from 20 - 90%) of the methyl
bromide used as a soil fumigaiu is released into the atmosphere; (ii) biomass burning: 10 to SO ktons per year, and
(iii) the exhaust of automobiles using leaded gasoline: 0.5 to 1 .5 ktons per year or 9 to 22 ktons per year (the two
studies report emission factors that differ by a factor of more than 10). In addition, the one known major natural
source of methyl bromide is oceanic, with emissions of 60 to 160 ktons per year.
101
Recent measurements have confirmed that there is more methyl bromide in the Northern Hemisphere than in the
Southern Hemisphere, with an interhemispheric ratio of 1.3.
There are two kjiown sinks for atmospheric methyl bromide: (i) atmospheric, with a lifetime of 2.0 years ( 1 .5 to
2.S years): and (ii) oceanic, with an estimated lifetime of 3.7 years ( 1 .5 to 10 years). The overall best estimate for
the lifetime of atmospheric methyl bromide is 1.3 years, with a range of 0.8 to 1.7 years. An overall lifetime of
less than 0.6 years is thought to be highly unlikely because of constraints imposed by the observed interhemi-
spheric ratio and total known emissions.
The chertiistry of bromine-induced stratospheric ozone destruction is now better understood. Laboratory mea-
surements have confirmed the fast rate for the BiO + HO? reaction and have established a negligible reaction
pathway producing HBr, both of which imply greater ozone losses due to emissions of compounds containing
bromine. Stratospheric measurements show that the abundance of HBr is less than I ppt.
Bromine is estimated to be about 50 times more efficient than chlorine in destroying stratospheric ozone on a per-
atom basis. The ODP for methyl bromide is calculated to be about 0.6, based on an overall lifetime of 1 .3 years.
An uncertainty analysis suggests that the ODP is unlikely to be less than 0.3.
Aircraft
Subsonics: Estimates indicate that present subsonic aircraft operations may be significantly increasing trace
species (primarily NO,, sulfur dioxide, and soot) at upper-tiopospheric altitudes in the North- Atlantic flight cor-
ridor. Models indicate that the NO, emissions from the current subsonic fleet produce upper-tropospheric ozone
increases as much as several percent, maximizing at northern midlatitudes. Since the results of these rather
complex models depend critically on NO, chemistry and since the tropospheric NO, budget is uncertain, little
confidence should be put in these quantitative model results at the present time.
Supersonics: Atmospheric effects of supersonic aircraft depend on the number of aircraft, the altitude of opera-
tion, the exhaust emissions, and the background chlorine and aerosol loadings. Projected fleets of supersonic
transports would lead to significant changes in trace-species concentrations, especially in the North-Atlantic
flight corridor. Two-dimensional model calculations of the impact of a projected fleet (500 aircraft, each emitting
15 grams of NO, per kilogram of fuel burned at Mach 2.4) in a stratosphere with a chlorine loading of 3.7 ppb,
imply additional {i.e., beyond those from halocarbon losses) annual-average ozone column decreases of
0.3 - 1.8% for the Northern Hemisphere. There are, however, important uncertainties in these model results,
especially in the stratosphere below 25 km. The same models fail to reproduce the observed ozone trends in the
stratosphere below 25 km between 1980 and 1990. Thus, these models may not be properly including mecha-
nisms that are important in this crucial altitude range.
Climate Effects: Reliable quantitative estimates of the effects of aviation emissions on climate are not yet avail-
able. Some initial estimates indicate that the climate effects of ozone changes resulting from subsonic aircraft
emissions may be comparable to those resulting from their CO2 emissions.
15 .
102
Oiome Depletion Potentials (ODPs)
• If a substance containing chlorine or bromine decomposes in the stratosphere, it will destroy some ozone.
HCFCs have short tropospheric lifetimes, which tends to reduce their impaa on stratospheric ozone as compared
to CFCs and halons. However, there are substantial differences in ODPs among varic.-!is substitutes. The steady-
state ODPs of substitute compounds considered in the present assessment range from about 0.01 - 0. 1 .
• Tropospheric degradation products of CFC substitutes will not lead to significant ozone loss in the stratosphere.
Those products will not accumulate in the atmosphere and will not significantly influence the ODPs and Global
Warming Potentials (GWPs) of the substitutes.
• Trifluoroacetic acid, formed in the atmospheric degradation of HFC-134a, HCFC-123, and HCFC-124, will enter
into the aqueous environment, where biological, rather than physico-chemical, removal processes may be effec-
tive.
• It is known that atomic fluorine (F) itself is not an efficient catalyst for ozone loss, and it is concluded that the
F-containing fragments from the substitutes (such as CF3O,) also have negligible impact on ozone. Therefore,
ODPs of MFCs contaimng the CF3 group (such as HFC- 134a, HFC-23, and HFC- 125) are likely to be much less
than 0.001.
• New laboratory measurements and associated modeling studies have confirmed that perfluorocarbons and suIAir
hexafluoride are long-lived in the atmosphere and act as greenhouse gases.
• The ODPs for several new compounds, such as HCFC-225ca, HCFC-225cb, and CF3I, have been evaluated using
both semi-empirical and modeling approaches, and are found to be 0.03 or less.
Global Warming Potentials (GWPs)
• Both the direct and indirect components of the GWP of methane have been estimated using model calculations.
Methane's influence on the hydroxyl radical and the resulting effect on the methane response time lead to substan-
tially longer response times for decay of emissions than OH removal alone, thereby increasing the GWP. In
addition, indirect effects including production of tropospheric ozone and stratospheric water vapor were consid-
ered and are estimated to range from about 15 to 45% of the total GWP (direct plus indirect) for methane.
• GWPs, including indirect effects of ozone depletion, have been estimated for a variety of halocaibons, clarifying
the relative radiative roles of ozone-depleting compounds (i.e., CFCs and halons). The net GWPs of halocarbons
depend strongly upon the effectiveness of each compound for ozone destruction; the halons are highly likely to
have negative net GWPs, while those of the CFCs are likely to be positive over both 20- and 100-year time
horizons.
Implications for Policy Formulation
The research findings of the past few years that are summarized above have several major implications as scientific
input to governmental, industrial, and other policy decisions regarding human-influenced substances that lead to deple-
tion of the stratospheric ozone layer and to changes of the radiative forcing of the climate system:
103
The Montreal Protocol and its Amendments and Adjustments are reducing the impact of anthropogenic
haiocarbons on the ozone layer and should eventually eliminate this ozone depletion. Based on assumed
compliance with the amended Montreal Protocol (Copenhagen, 1992) by all nations, the stratospheric chlorine
abundances will continue to grow from their current levels (3.6 ppb) to a peak of about 3.8 ppb around the turn of
the century. The future total bromine loading will depend upon choices made regarding future human production
and emissions of methyl bromide. After around the turn of the century, the levels of stratospheric chlorine and
bromine will begin a decrease that will continue into the 21st and 22nd centuries. The rate of decline is dictated
by the long residence times of the CFCs, carbon tetrachloride, and halons. Global ozone losses and the Antarctic
ozone "hole" were first discernible in the late 1970s and are predicted to recover in about the year 2045, other
things being equal. The recovery of the ozone layer would have been impossible without the Amendments and
Adjustments to the original Protocol (Montreal, 1987).
Peak global ozone losses are expected to occur during the next several years. The ozone layer will be most
affected by human-influenced perturbations and susceptible to natural variations in the period around the year
1998, since the peak stratospheric chlorine and bromine abundances are expected to occur then. Based on extrap-
olation of current trends, observations suggest that the maximum ozone loss, relative to the late 1960s, will likely
be:
(i) about 12 - 13% at Northern tnidlatitudes in winter/spring (i.e., about 2.5% above current levels);
(ii) about 6 - 7% at Northern midlatitudes in summer/fall (i.e., about 1 .5% above current levels); and
(iii) about 11% (with less certainty) at Southern midlatitudes on a year-round basis {i.e., about 2.5% above
current levels).
Such changes would be accompanied by 15%, 8%, and 13% increases, respectively, in surface erythemal radia-
tion, if other influences such as clouds remain constant. Moreover, if there were to be a major volcanic eruption
like that of Mt. Pinatubo, or if an extremely cold and persistent Arctic winter were to occur, then the ozone losses
and UV increases could be larger in individual years.
Approaches to lowering stratospheric chlorine and bromine abundances are limited. Further controls on
ozone-depleting substances would not be expected to significantly change the timing or the magnitude of the peak
stratospheric halocarbon abundances and hence peak ozone loss. However, there are four approaches that would
steepen the initial fall from the peak halocarbon levels in the early decades of the next century:
(i) If emissions of methyl bromide from agricultural, structural, and industrial activities were to be eliitiinated
in the year 200 1 , then the integrated effective future chlorine loading above the 1 980 level (which is related
to the cumulative future loss of ozone) is predicted to be 13% less over the next 50 years relative to full
compliance to the Amendments and Adjustments to the Protocol.
(ii) If emissions of HCFCs were to be totally eliminated by the year 2004, then the integrated effective future
chlorine loading above the 1980 level is predicted to be 5% less over the next 50 years relative to full
compliance with the Amendments and Adjustments to the Protocol,
(iii) If halons presently contained in existing equipment were never released to the atmosphere, then the inte-
grated effective future chlorine loading above the 1980 level is predicted to be 10% less over the next 50
years relative to full compliance with the Amendments and Adjustments to the Protocol.
(iv) If CFCs presently contained in existing equipment were never released to the atmosphere, then the integrat-
ed effective future chlorine loading above the 1980 level is predicted to be 3% less over the next 50 years
relative to full compliance with the Amendments and Adjustments to the Protocol.
iZ
104
ctolheMenHfiaMlapccacatiwadeii^reMvetyaftteaaaeiiT^K If iboe were u> be
addUoMl imdKtiM of CFCt « 20% of 1992 le»eb Sdt eacfa 3iear dn^ 2002 Md camped lo zm> by 20M
rill Jill Ih ■*!■ Ill fi —liiinii [■'■i.iiilii liliili Tiirilt TlliMii iiriiilninT) Itiinllir iwrirTilrffrnr r
fmmt diadtc loodag above tte 1980 lewd tt ptedicied to be 9% oxve over (he aoa SO yean lebiive lo fall
s Kt *e AaeadMoB Md AAMOaeaB 19 te Proioco!
ifarlheCFCs^hilMiMeilMa0UUegreenbciDsega*eL Sevstal CFC and hakn
t aK aot addhNKd Mder dK Moatneil Pnioool (becave Aejr do aot depieie ozooe). bai, becaoie ibey
tin I- fill — I* I Il» iwiii ■ nf Ih rrwiminri rnmrnrinn nn rtimtr TTi-wtr Tbereiiawide
fM^ of nlKt fior «K Caobol WtasMc I^NBMiak (GWPt) of ibe HPCf M50 - 10000). widi aboM baif of ifaem
hawag iAifHMMtMiiUeio*eazo«6Hieplati«guMtK— ilnbgrrepbce. Tbe perflaomaied compoaadi. sooie
<rf wbitfc a» beiae iwiidterBd a» iriiiii—pg. hwe vpy taiBe GWP» (eg., 5000 10000). Hkk ape examples of
mill— li mh Mil 1 ■1111*1 lii ii—ilwi 1 1 ■! n l»iii Ij iiiiJI Urn ui i iiij m iniirt ■rrnir "w rtir
f*3re
CwM*de»aB— af a»«<^ rhuiff wMbeaae ifffgy iyr^h^ ia aailiiilMiaiufciate rhMff Tbe
e»ieMofo«rabaiQrio«iii—r aaycawmettoriyioapeaficcaBKt will Ifltety prove w be importaaKJeatific
■p«tiod8CMiowirt,BiaitpBedK»edbBMa»-««dacedi^lBe«ct»OBftediaiaiety«eni. Qtaage* ia ozone noce
pte-iadaMtBi daes at a Knh of baana acbvky are beiiewed to bi»e beea a tagaificaat isflueace oa radiative
fiwiat.fcibaiaMiaflararr ii rrfrnriin rnnriaar iTilir fnrrr-riHr frrrr
105
Common Questions about Ozone
Ozone is exceedingly rare in our atmosphere,
averaging about 3 molecules of ozone lor
every ten million air molecules. Nonettie-
less, atmospheric ozone plays vital roles that belie its
small numbers. This Appendix to the World Meteoro-
logical Organization/United Nations Environrver)!
Programme (WMO/UNEP) Scientific Assessment of
Ozone Depletion: 1994 answers some of the questions
that are most commonly asked about ozone and the
changes that have been occurring in recent years These
common questions and their answers were discussed by
the 80 scientists from 26 countries who participated in
the Panel Review Meeting of the Scientific Assessment of
Ozone Depletion: 1994. Therefore, this information Is
presented by a large group of experts from the interna-
tional scientific community
Ozone is mainly found in two regions of the Earth's atmo-
sphere. Most ozone (about 90%) resides in a layer
between approximately 10 and 50 kilometers (about 6 to
30 miles) above the Earth's surface, in the region of the
atmosphere called the stratosphere. This stratospheric
ozone is commonly known as the "ozone layer." The re-
maining ozone is in the lower region of the atmosphere,
the troposphere, which extends from the Earth's surface
up to about 10 kilometers The figure below shows this
distribution of ozone in the atmosphere.
While the ozone in these two regions is chemically iden-
tical (both consist of three oxygen atoms and have the
chemical formula "O3"), the ozone molecules have very
different effects on humans and other living things de-
pending upon their location.
Stratospheric ozone plays a beneficial role by absorbing
most of the biologically damaging ultraviolet sunlight
called UV-B, allowing only a small amount to reach the
Earth's surface. The absorption of UV radiation by ozone
creates a source of heat, which actually forms the strato-
sphere itself (a region in which the temperature rises as
one goes to higher altitudes). Ozone thus plays a key
role in the temperature structure of the Earth's atmo-
sphere Furthermore, without the filtering action of the
ozone layer, more of the Sun's UV-B radiation would
penetrate the atmosphere and would reach the Earth's
surlace in greater amounts. Many experimental studies
of plants and animals, and clinical studies of humans,
have shown the harmful effects of excessive exposure to
UV-B radiation {these are discussed in the WMO/UNEP
reports on impacts of ozone depletion, which are com-
panion documents to the WMO/UNEP sclentHic assess-
ments of ozone depletion).
At the planet's surface, ozone comes into direct contact
with life-forms and displays its destructive side. Be-
cause ozone reacts strongly with other molecules, high
levels are toxic to living systems and can severely dam-
age the tissues of plants and animals. Many studies
have documented the harmful effects of ozone on crop
production, forest growth, and human health. The sub-
stantial negative effects of surface-level tropospheric
ozone from this direct toxicity contrast with the benefits
of the additional filtering of UV-B radiation that it pro-
vides.
With these dual aspects of ozone come two separate en-
vironmental issues, controlled by different forces in the
atmosphere. In the troposphere, there is concern about
increases in ozone. Low-lying ozone is a key component
of smog, a familiar problem in the atmosphere of many
cities around the world. Higher than usual amounts of
surface-level ozone are now increasingly being observed
in rural areas as well. However, the ground-level ozone
concentrations in the smoggiest cities are very much
smaller than the concentrations routinely found in the
stratosphere.
There is widespread scientific and public interest and
concern about losses of stratospheric ozone. Ground-
based and satellite instruments have measured
decreases in the amount of stratospheric ozone in our
atmosphere. Over some parts of Antarctica, up to 60% of
the total overhead amount of ozone (known as the "col-
umn ozone") is depleted during September and October.
This phenomenon has come to be known as the Antarctic
"ozone hole " Smaller, but still significant, stratospheric
decreases have been seen at other, more-populated re-
gions of the Earth. Increases in surface UV-B radiation
have been observed in association with decreases in
stratospheric ozone.
The scientific evidence, accumulated over more than two
decades of study by the international research communi-
ty, has shown that human-made chemicals are
responsible for the observed depletions of the ozone lay-
er over Antarctica and likely play a major role m global
ozone losses. The ozone-depleting compounds contain
various combinations of the chemical elements chlorine,
fluorine, bromine, carbon, and hydrogen, and are often
described by the general term t)alocarbOns. The com-
106
pounds that contain only carbon, chlorine, and fluorine
are called chlorofluorocarbons. usually aobreviated as
CFCs. CFCs, carbon tetrachloride, and methyl chloro-
form are important human-made ozone-depleting gases
that have been used in many applications including re-
frigeration, air conditioning, foam blowing, cleaning of
electronics components, and as solvents. Another im-
portant group of human-made halocarbons is the
halons, which contain carbon, bromine, fluorine, and (in
some cases) chlorine, and have been mainly used as fire
extinguishants. Governments have decided to discon-
tinue production of CFCs, halons, carbon tetrachloride,
and methyl chloroform, and industry has developed
more "ozone-friendly" substitutes.
Two responses are natural when a new problem has been
identified: cure and prevention. When the problem is the
destruction of the stratospheric ozone layer, the corre-
sponding questions are; Can we repair the damage
already done? How can we prevent further destruction?
Remedies have been investigated that could (i) remove
CFCs selectively from our atmosphere, (ii) intercept
ozone-depleting chlorine before much depletion has tak-
en place, or (iii) replace the ozone lost in the stratosphere
(perhaps by shipping the ozone from cities that have too
much smog or by making new ozone). Because ozone
reacts strongly with other molecules, as noted above, it
is too unstable to be made elsewhere (e.g.. in the smog
of cities) and transported to the stratosphere. When the
huge volume of the Earth's atmosphere and the magni-
tude of global stratospheric ozone depletion are carefully
considered, approaches to cures quickly become much
too expensive, impractical, and potentially damaging to
the global environment. Prevention involves the interna-
tionally agreed-upon Montreal Protocol and its
Amendments and Adjustments, which call for elimina-
tion of the production and use of the CFCs and other
ozone-damaging compounds within the next few years.
As a result, the ozone layer is expected to recover over
the next fifty years or so as the atmospheric concentra-
tions of CFCs and other ozone-depleting compounds
slowly decay
The current understanding of ozone depletion and its re-
lation to humankind is discussed in detail by the leading
scientists in the world's ozone research community in the
Scientific Assessment of Ozone Depletion: 1994. The
answers to the common questions posed below are
based upon that understanding and on the information
given in earlier WMOAJNEP reports.
Atmospheric Ozone
Stratospheric Ozone
(The Ozone Layer)
Tropospheric Ozone
• Contains 90% of Atmosphenc
Ozone
• Beneficial Role:
Acts as Pfimary UV Radiation
ShieU
• Current Issues:
- Ijng-term Gkibal
Downward Trends
- Springtime Antarctic Ozone
Hole Each Year
' Contains 10% of Atmospheric
Ozone
• Harmful Impact: Toxic Effects
on Humans and Vegetation
• Current Issues:
- Episodes of High Surface
Ozone in Urt>an and
Rural Areas
Ozone Amount
(pressure, milli-Pascals)
20
107
How Can Chlorofluorocarbons (CFCs) Get to the Stratosphere
If They're Heavier than Air?
Although the CFC molecules are indeed several times
heavier than air, thousands of measurements have been
made Irom balloons, aircraft, and satellites demonstrat-
ing that the CFCs are actually present in the stratosphere.
The atmosphere is not stagnant. Winds mix the atmo-
sphere to altitudes far above the top of the stratosphere
much faster than molecules can settle according to their
weight Gases such as CFCs that are insoluble in vtrater
and relatively unreactive in the lower atmosphere (below
about 10 km) are quickly mixed and therefore reach the
stratosphere regardless of their weight.
Much can be learned about the atmospheric fate of com-
pounds from the measured changes in concentration
versus altitude. For example, the two gases carbon tet-
rafluoride (CF4, produced mainly as a by-product of the
manufacture of aluminum) and CFC-1 1 (CCI3F, used in a
variety of human activities) are both much heavier than
air. Carbon tetrafluoride is completely unreactive in the
lower 99.9% of the atmosphere, and measurements
show it to be nearly uniformly distributed throughout the
atmosphere as shown in the figure. There have also been
measurements over the past two decades of several other
completely unreactive gases, one lighter than air (neon)
and some heavier than air (argon, krypton), which show
that they also mix upward uniformly through the strato-
sphere regardless of their weight, just as observed with
carbon tetrafluoride. CFC-11 is unreactive in the lower
atmosphere (below about 15 km) and is similarly uni-
formly mixed there, as shown. The abundance of
CFC-11 decreases as the gas reaches higher altitudes,
where it is broken down by high energy solar ultraviolet
radiation. Chlorine released from this breakdown of
CFC-11 and other CFCs remains in the stratosphere for
several years, where it destroys many thousands of mol-
ecules of ozone.
Measurements of CFC-11 and CF4
40
v>
CF4
V
•Vn^CFC-ll
•5 30
^^....^^^^^^^
0
^^^^
JC
^^^^^
« 20
-
s.
■5?
X
«-
< 10
1 1 1 1
1. 1
0.01 ai 1.0 10.0 100
Atmospheric Abundance
( in ports per trillion )
1000
Stratosphere
/WW
Trcposptiere
108
What is the Evidence that Stratospheric Ozone
is Destroyed by Chlorine and Bromine?
Laboratory studies show that chlorine (CI) reacts very
rapidly with ozone They also show that the reactive
chemical chlorine oxide (CIO) formed in that reaction
can undergo further processes which regenerate the
original chlorine, allowing the sequence to be repeated
very many times (a "chain reaction"). Similar reactions
also take place between bromine and ozone.
But do these ozone-destroying reactions occur in the real
world? All of our accumulated scientific experience dem-
onstrates that if the conditions of temperature and
pressure are like those in the laboratory studies, the
same chemical reactions will take place in nature. How-
ever, many other reactions including those of other
chemical species are often also taking place simulta-
neously in the stratosphere, making the connections
among the changes difficult to untangle. Nevertheless,
whenever chlorine (or bromine) and ozone are found to-
gether in the stratosphere, the ozone-destroying
reactions must be taking place.
Sometimes a small number of chemical reactions is so
important in the natural circumstance that the connec-
tions are almost as clear as in laboratory experiments.
Such a situation occurs in the Antarctic stratosphere dur-
ing the springtime formation of the ozone hole. During
August and September 1987 - the end of winter and be-
ginning of spring in the Southern Hemisphere - aircraft
equipped with many different instruments for measuring
a large number of chemical species were flown repeated-
ly over Antarctica. Among the chemicals measured were
ozone and chlorine oxide, the reactive chemical identi-
fied in the laboratory as one of the participants in the
ozone-destroying chain reactions. On the first flights
southward from the southern tip of South America, rela-
tively high concentrations of ozone were measured
everywhere over Antarctica. By mid-September, howev-
er, the instruments recorded low concentrations of ozone
in regions where there were high concentrations of chlo-
rine oxide and vice versa, as shown in the figure. Flights
later in September showed even less ozone over Antarc-
tica, as the chlorine continued to react with the
stratospheric ozone.
independent measurements made by these and other in-
struments on this and other airplanes, from the ground,
from balloons, and from satellites have provided a de-
tailed understanding of the chemical reactions going on
in the Antarctic stratosphere. Regions with high concen-
trations of reactive chlorine reach temperatures so cold
(less than approximately -SOX, or -112°F) that strato-
spheric clouds form, a rare occurrence except during the
polar winters. These clouds facilitate other chemical re-
actions that allow the release of chlorine in sunlight. The
chemical reactions related to the clouds are now well
understood through study under laboratory conditions
mimicking those found naturally. Scientists are working
to understand the role of such reactions of chlorine and
bromine at other latitudes, and the involvement of parti-
cles of sulfuric acid from volcanoes or other sources.
Measurements of Ozone and Reactive Chlorine
from a Fiiglit into tlie Antarctic Ozone Hoie
2S00
* ,-v Own*
2000
'x A /
'
,«»
■^^w'l
(ScaJe «i RiflW) J
Afltarac
PoiaiA-
Latitude {D»gr»«s Sou*i)
109
Does Most of the Chlorine in the Stratosphere
Come from Human or Natural Sources?
Most of the chlorine in the stratosphere is there as a re-
sult of human activities.
Many compounds containing chlorine are released at the
ground, but those that dissolve in water cannot reach
stratospheric altitudes. Large quantities of chlorine are
released from evaporated ocean spray as sea salt (sodi-
um chloride) aerosol. However, because sea salt
dissolves in water, this chlorine quickly is taken up in
clouds or in ice, snow, or rain droplets and does not
reach the stratosphere. Another ground-level source of
chlorine is its use in swimming pools and as household
bleach. When released, this chlorine is rapidly convert-
ed to forms that dissolve in water and therefore are
removed from the lower atmosphere, never reaching the
stratosphere in significant amounts. Volcanoes can emit
large quantities of hydrogen chloride, but this gas is rap-
idly converted to hydrochloric acid in rain water, ice, and
snow and does not reach the stratosphere. Even in ex-
plosive volcanic plumes that rise high in the atmosphere,
nearly all of the hydrogen chloride is scrubbed out in
precipitation before reaching stratospheric altitudes.
In contrast, human-made halocarbons - such as CFCs,
carbon tetrachloride (CCU) and methyl chloroform
(CH3CCI3) - are not soluble in vrater, do not react with
snow or other natural surfaces, and are not broken down
chemically in the lower atmosphere. While the exhaust
from the Space Shuttle and from some rockets does in-
ject some chlorine directly into the stratosphere, this
input is very small (less than one percent of the annual
input from halocarbons in the present stratosphere, as-
suming nine Space Shuttle and six Titan IV rocket
launches per year).
Several pieces of evidence combine to establish human-
made halocarbons as the primary source of stratospheric
chlorine. First, measurements (see the figure tjelow)
have shown that the chlorinated species that rise to the
stratosphere are primarily manufactured compounds
(mainly CFCs, carbon tetrachloride, methyl chloroform,
and the HCFC substitutes for CFCs), together with small
amounts of hydrochloric acid (HCI) and methyl chloride
(CH3CI) which are partly natural in origin. The natural
contribution now is much smaller than that from human
activities, as shown in the figure below. Second, in 1985
and 1992 researchers measured nearly all known gases
containing chlorine in the stratosphere. They found that
human emissions of halocarbons plus the much smaller
contribution from natural sources could account for all of
the stratospheric chlorine compounds. Third, the in-
crease in total stratospheric chlorine measured between
1985 and 1992 corresponds with the known increases in
concentrations of human-made halocarbons during that
time.
Primary Sources of Chlorine Entering the Stratosphere
no
Can Changes in the Sun's Output Be Responsible
for the Observed Changes in Ozone?
stratospheric ozone is primarily created by ultraviolet
(UV) ligtit coming from the Sun. so the Sun's output af-
fects the rate at which ozone is produced. The Sun's
energy release (both as UV light and as charged particles
such as electrons and protons) does vary, especially
over the well-known 11 -year sunspot cycle. Observa-
tions over several solar cycles (since the 1960s) show
that total global ozone levels decrease by 1-2% from the
maximum to the minimum of a typical cycle. Changes in
the Sun's output cannot be responsible for the observed
long-term changes in ozone, because these downward
trends are much larger than 1-2%. Further, during the
period since 1979, the Sun's energy output has gone
from a maximum to a minimum in 1985 and back
through another maximum in 1991, but the trend in
ozone was downward throughout that time. The ozone
trends presented in this and previous international sci-
entific assessments have been obtained by evaluating
the long-term changes in ozone concentrations after ac-
counting for the solar influence (as has been done in the
figure below).
Global Ozone Trend (60°S-60°N)
1960
1982
1984
1986 1988
Year
1990
1992
1994
»
Ill
When Did the Antarctic Ozone Hole First Appear?
The Antarctic ozone tiole is a new phenomenon. The fig-
ure shows that observed ozone over the British Antarctic
Survey station at Halley Bay, Antarctica first revealed ob-
vious decreases in the early 1980s compared to data
obtained since 1957. The ozone hole is formed each
year when there is a sharp decline (currently up to 60%)
in the total ozone over most of Antarctica for a period of
about two months during Southern Hemisphere spring
(September and October). Observations from three other
stations in Antarctica, also covering several decades, re-
veal similar progressive, recent decreases in springtime
ozone. The ozone hole has been shown to result from
destruction of stratospheric ozone by gases containing
chlorine and bromine, whose sources are mainly hu-
man-made halocarbon gases.
Before the stratosphere vras affected by human-made
chlorine and bromine, the naturally occurring springtime
ozone levels over Antarctica were about 30-40% lower
than springtime ozone levels over the Arctic. This natu-
ral difference between Antarctic and Arctic conditions
was first observed in the late 1 950s by Dobson. It stems
from the exceptionally cold temperatures and different
winter wind patterns within the Antarctic stratosphere as
compared to the Arctic. This is not at all the same phe-
nomenon as the marked downward trend in total ozone in
recent years referred to as the ozone hole and shown in
the figure below.
Changes in stratospheric meteorology cannot explain
the ozone hole. Measurements show that wintertime
Antarctic stratospheric temperatures of past decades
have not changed prior to the development of the hole
each September. Ground, aircraft, and satellite measure-
ments have provided, in contrast, clear evidence of the
importance of the chemistry of chlorine and bromine
originating from human-made compounds in depleting
Antarctic ozone in recent years.
A single report of extremely low Antarctic winter ozone in
one location in 1958 by an unproven technique has been
shown to be completely inconsistent with the measure-
ments depicted here and with all credible measurements
of total ozone.
Historical Springtime Totai Ozone Record
for Halley Bay, Antarctica (76°S)
112
Why is the Ozone Hole Observed over Antarctica
When CFCs Are Released Mainly in the Northern Hemisphere?
Human emissions of CFCs do occur mainly in the North-
ern Hemisphere, with about 90% released in the
latitudes corresponding to Europe, Russia, Japan, and
North America. Gases such as CFCs that are insoluble in
water and relatively unreactlve are mixed within a year or
two throughout the lower atmosphere (below about 10
km). The CFCs in this well-mixed air rise from the lower
atmosphere into the stratosphere mainly in tropical lati-
tudes. Winds then move this air poleward - both north
and south - from the tropics, so that air throughout the
stratosphere contains nearly the same amount of chlo-
rine. However, the meteorologies of the two polar
regions are very different from each other because of
major differences at the Earth's surface. The South Pole
is part of a very large land mass (Antarctica) that is com-
pletely surrounded by ocean. These conditions produce
very low stratospheric temperatures which in turn lead to
formation of clouds (polar stratospheric clouGs). The
clouds that form at low temperatures lead to chemical
changes that promote rapid ozone loss during Septem-
ber and October of each year, resulting in the ozone hole.
In contrast, the Earth's surface in the northern polar re-
gion lacks the land/ocean symmetry characteristic of the
southern polar area. As a consequence, Arctic strato-
spheric air is generally much warmer than in the
Antarctic, and fewer clouds form there. Therefore, the
ozone depletion in the Arctic is much less than In the
Antarctic.
1979
Schematic of Antarctic Ozone Hole
1986
1991
26
113
Is the Depletion of the Ozone Layer Leading to an Increase in
Ground-Level Ultraviolet Radiation?
The Sun emits light over a wide range of energies, with
about two percent given oft in the form of high-energy,
ultraviolet (UV) radiation. Some of this UV radiation
(UV-B) is especially effective in causing damage to living
things, including sunburn, skin cancer, and eye damage
for humans. The amount of solar UV radiation received
at any particular location on the Earth's surface depends
upon the position of the Sun above the horizon, on the
amount of ozone in the atmosphere, and upon local
cloudiness and pollution. Scientists agree that in the ab-
sence of changes in clouds or pollution, decreases In
atmospheric ozone will increase ground-level UV radia-
tion.
The largest decreases in ozone during the last decade
have been observed over Antarctica, especially during
each September and October when the "ozone hole"
forms. During the last several years, simultaneous mea-
surements of UV radiation and total ozone have been
made at several Antarctic stations. As shown in the fig-
ure below, when the ozone amounts decrease, UV-B
increases. Because of the ozone hole, the UV-B intensity
at Palmer Station, Antarctica, in late October, 1993, was
more intense than found at San Diego, California, at any
time during all of 1993.
In areas where small ozone depletion has been observed,
UV-B increases are more difficult to detect. Detection of
UV trends associated with ozone decreases can also be
complicated by changes in cloudiness or by local pollu-
tion, as well as by difficulties in keeping the detection
instrument in precisely the same condition over many
years. Prior to the late 1980s, instruments with the nec-
essary accuracy and stability for measurement of small
long-term trends in ground-level UV-B were not em-
ployed. Recently, however, such instruments have been
used in the Antarctic because of the very large changes
in ozone being observed there. When high-quality mea-
surements have been made in other areas far from major
cities and their associated air pollution, decreases in
ozone have regularly been accompanied by increases in
UV-B. The data from urban locations with older, less
specialized instruments provide much less reliable infor-
mation, especially because good simultaneous
measurements are not available for any changes in
cloudiness or local pollution.
Increases in Erythemal (Sunburning) UV Radiation
Due to Ozone Reductions
South Pole, Antorctico
Feb 1991 - Oec 1992
-40%
Chonge In Ozone
( Spring vs. Autumn, for the Some Solar Angle)
27
114
How Severe Is the Ozone Depletion Now,
and Is It Expected to Get Worse?
Scientific evidence shows that ozone depletion caused
by human-made chemicals is continuing and is expected
to persist until chlorine and bromine levels are reduced.
Worldwide monitoring has shown that stratospheric
ozone has been decreasing for the past two decades or
more. Globally averaged losses have totaled about 5%
since the mid-1960s, with cumulative losses of about
10% in the winter and spring and 5% in the summer and
autumn over locations such as Europe, North America,
and Australia. Since the late-1970s, an ozone "hole" has
formed in Antarctica each Southern Hemisphere spring
(September / October), in which up to 60% of the total
ozone is depleted. The large increase in atmospheric
concentrations of human-made chlorine and bromine
compounds is responsible for the formation of the Ant-
arctic ozone hole, and the weight of evidence indicates
that it also plays a major role in midlatitude ozone deple-
tion.
During 1 992 and 1 993 ozone in many locations dropped
to record low values: springtime depletions exceeded
20% in some populated northern midlatitude regions,
and the levels in the Antarctic ozone hole fell to the low-
est values ever recorded. The unusually large ozone
decreases of 1992 and 1993 are believed to be related, in
part, to the volcanic eruption of IVIount Pinatubo in the
Philippines during 1991. This eruption produced large
Ozone-Dorrxiging Stratospheric Chlorine/BrDmine
15000
•~ 12000
c
.9 I
'B
!a 9000
•
1
Protocol / /.
-
/ /
■
/ /
.
/■ /
.
/■ /
.
:
/ / ■
•
/ y
•
/
y
1 ■ ■ ■ ■ 1
1950 »I975 ZqpC aces 2050 2075 2100
amounts of stratospheric sulfate aerosols that temporari-
ly increased the ozone depletion caused by human-made
chlorine and bromine compounds. Recent observations
have shown that as those aerosols have been swept out
of the stratosphere, ozone concentrations have returned
to the depleted levels consistent with the downward trend
observed before the Mount Pinatubo eruption.
In 1987 the recognition of the potential lor chlorine and
bromine to destroy stratospheric ozone led to an interna-
tional agreement (The United Nations Montreal Protocol
on Substances that Deplete the Ozone Layer) to reduce
the global production of ozone-depleting substances.
Since then, new global observations of significant ozone
depletion have prompted amendments to strengthen the
treaty. The 1992 Copenhagen Amendments call for a ban
on production of the most damaging compounds by
1996. The figure shows past and projected future strato-
spheric abundances of chlorine and bromine: (a) without
the Protocol; (b) under the Protocol's original provi-
sions; and (c) under the Copenhagen Amendments now
in force. Without the Montreal Protocol and its Amend-
ments, continuing human use of CFCs and other
compounds would have tripled the stratospheric abun-
dances of chlorine and bromine by about the year 2050.
Current scientific understanding indicates that such in-
creases would have led to global ozone depletion very
much larger than observed today. In contrast, under cur-
rent international agreements, which are now reducing
and will eventually eliminate human emissions of ozone-
depleting gases, the stratospheric abundances of
chlorine and bromine are expected to reach their maxi-
mum within a few years and then slowly decline. All
other things being equal, the ozone layer is expected to
return to normal by the middle of the next century.
In summary, record low ozone levels have been observed
in recent years, and substantially larger future global de-
pletions in ozone would have been highly likely without
reductions in human emissions of ozone-depleting gas-
es. However, worldwide compliance with current
international agreements is rapidly reducing the yearly
emissions of these compounds. As these emissions
cease, the ozone layer will gradually improve over the
next several decades. The recovery of the ozone layer
will be gradual because of the long times required for
CFCs to be removed from the atmosphere.
^^
115
List of International Authors,
Contributors, and Reviewers
Assessment Co-chairs
Daniel L. Albritton, Robert T. Watson, and Piet J. Aucamp
Chapters and Lead Authors
Part 1 . Observed Changes in Ozone and Source Gases
Chapter 1. Ozone Measurements (Neil R. P. Harris)
Chapter 2. Source Gases: Trends and Budgets (Eugenia Sanhueza)
Part 2. Atmospheric Processes Responsible for the Observed Changes in Ozone
Chapter 3. Polar Ozone (David W Fahey)
Chapter 4. Tropical and Midlatitude Ozone (Roderic L Jones)
Chapters. Tropospheric Ozone (Andreas Voh-Thomas and Brian A. Ridley)
Part 3. Model Simulations of Global Ozone
Chapter 6. Model Simulations of Stratospheric Ozone (Malcolm K. W. Ko)
Chapter?. ModelSimulationsof Global Tropospheric Ozone (Frode Stordal)
Part 4. Consequences of Ozone Change
Chapter 8. Radiative Forcing and Temperattire Trends (Keith P. Shine)
Chapter 9. Surface Ultraviolet Radiation (Richard L McKenzie)
Part 5. Scientific Information for Future Decisions
Chapter 10. Methyl Bromide (Stuart A. Penkett)
Chapter 1 1 . Subsonic and Supersonic Aircraft Emissions (Andreas Wahner and Marvin A. Getler)
Chapter 12. Atmospheric Degradation of Halocarbon Substimtes (R.A. Cox)
Chapter 13. Ozone Depletion Potentials, Global Warming Potentials, and
Future Chlorine/Bromine Loading (Susan Solomon and Donald J. Wuebbles)
Coordinators: Common Questions About Ozofie
Susan Solomon NOAA Aeronomy Laboratory US
F. Sherwood Rowland University of California at Irvine US
Authors, Contributors, and Reviewers
Daniel L. Albritton NOAA Aeronomy Laboratory US
Marc Allaan Koninklijk Nederlands Meteorologisch Instituut The Netheriands
FredN. Alyea Georgia Institute of Technology US
Gerard Ancellet Centre National de la Recherche Scientifique France
Meinrat O. Andreae Max-Planck-Institut fiir Chemie Germany
James K. Angell NOAA Air Resources Laboratory US
Frank Arnold Max-Planck-Institut fUr Kemphysik Germany
116
Roger Atkinson University of California at Riverside US
Elliot Atlas National Center for Atmospheric Research US
Piet J. Aucamp Department of Health South Africa
Linnea M. Avallone University of California at Irvine US
Helmuth Bauer Forschungszentrum fUr Umwelt u. Gesundheit Germany
Slimane Bekki University of Cambridge UK
Tibor B£rces Hungarian Academy of Sciences Hungary
T. Bemtsen Universitetet I Oslo Norway
Lane Bishop Allied Signal US
Donald R. Blake University of California at Irvine US
N.J.Blake University of California at Irvine US
Mario Blumthaler University of Innsbruck Austria
Greg E. Bodeker University of Natal/NTWA South Africa
Rumen D. Bojkov World Meteorological Organization Switzerland
Charles R. Booth Biospherical Instruments US
Byron Boville National Center for Atmospheric Research US
Kenneth P. Bowman Texas A&M University US
Geir Braathen Norsk Institutt for Luftforskning Norway
Guy P. Brasseur National Center for Atmospheric Research US
Carl Brenninkmeijer National Institute of Water and Atmospheric Research New Zealand
Christoph Brilhl Max-Planck-Institut fUr Chemie Germany
William H. Brune Pennsylvania State University US
James H. Butler NOAA Climate Monitoring and Diagnostics Laboratory US
Sergio Cabrera Universidad de Chile Chile
Bruce A. Callander United Kingdom Meteorological Office UK
Daniel Cariolle M£t£o-France, Centre National de Recherches M£t£otologiques France
RichanJ P. Cebula Hughes STX US
William L. Chameides Georgia Institute of Technology US
Sushil Chandra NASA Goddard Space Right Center US
Marie-Lise Chanin Centre National de la Recherche Scientifique France
J.Christy University of Alabama at Huntsville US
Ralph J. Cicerone University of California at Irvine US
G.J.R. Coetzee Weather Bureau South Africa
Peter S. Connell Lawrence Livermore National Laboratory US
D. Considine NASA Goddard Space Right Center US
R.A. Cox National Environmental Research Council UK
Paul J. Ciutzen Max-Planck-Institut fUr Chemie Germany
Derek N. Cunnold Georgia Institute of Technology US
John Daniel NOAA Aeronomy Laboratory/CIRES US
Malgorzata Deg6rska Polish Academy of Sciences Poland
John J. DeLuisi NOAA Air Resources Laboratory US
Dirk De Muer Institut Royal M£t£orologique de Belgique Belgium
Frank Dentener Wageningen Agricultural University The Netherlands
Richard G. Derwent UK Meteorological Office UK
Terry Deshler University of Wyoming US
Susana B. Diaz Austral Center of Scientific Research (CADIC/CONICET) Argentina
Russell Dickerson University of Maryland US
117
J. Dignon Lawrence Livermore National Laboratory
Ed Dlugokencky NOAA Climate Monitoring and Diagnostics Laboratory
Anne R. Douglass NASA Goddard Space Flight Center
Tom Duafala Methyl Bromide Global Coalition
James E. Dye National Center for Atmospheric Research
Dieter H. Ehhalt Forschungszentnim JUlich
James W. Elkins NOAA Climate Monitoring and Diagnostics Laboratory
Christine Ennis NOAA Aeronomy Laboratory/CIRES
D. Etheridge CSIRO Division of Atmospheric Research
David W. Fahey NOAA Aeronomy Laboratory
T. Duncan A. Fairlie NASA Langley Research Center
Donald A. Fisher E.I. DuPont de Nemours and Company
Jack Fishman NASA Langley Research Center
Eric L. Fleming Applied Research Corporation
Frank Flocke Forschungszentnim JUlich
Lawrence E. Flynn Software Corporation of America
P.M. de F. Fbrster University of Reading
James Franklin Solvay S.A.
Paul J. Eraser CSIRO Division of Atmospheric Research
John E. Frederick University of Chicago
Lucien Froidevaux California Institute of Technology/Jet Propulsion Laboratory
J.S. Fuglestvedt Center for International Climate & Energy Research
Reinhard Furrer Freie UniversitSt Berlin
Ian E. Galbally CSIRO Division of Atmospheric Research
Brian G. Gardiner British Antarctic Survey
Marvin A. Geller State University of New York at Stony Brook
Hartwig Gemandt Alfred Wegener Institut
James F. Gleason NASA Goddard Space Flight Center
Sophie Godin Centre National de la Recherche Scientifique
Amram Golombek Israel Institute for Biological Research
Ulrich GOrsdorf Deutscher Wetterdienst
Thomas E. Graedel AT&T Bell Laboratories
Claire Granier National Center for Atmospheric Research
William B. Grant NASA Langley Research Center
L J. Gray SERC Rutherford Appleton Laboratory
William L. Grose NASA Langley Research Center
J. Gross Max-Planck-Institut fUr Cbemie
A.S. Grossman Lawrence Livermore National Laboratory
Alexander Gruzdev Russian Academy of Sciences
James E. Hansen NASA Goddard Institute for Space Studies
Neil R.P. Harris European Ozone Research Coordinating Unit
Shiro Hatekeyama National Institute for the Environment
D.A. Hauglustaine Centre National de la Recherche Scientifique
Sachiko Hayashida Nara Women's University
G.D. Hayman Harwell Laboratory/AEA Environment and Energy
Kjell Heniiksen University of Troms0
Emest Hilsenrath NASA Goddard Space Flight Center
US
US
US
US
US
Germany
US
US
Australia
US
US
US
US
US
Germany
US
UK
Belgium
Australia
US
US
Norway
Germany
Australia
UK
US
Germany
US
France
Israel
Germany
US
US
US
UK
US
Germany
US
Russia
US
UK
Japan
France
Japan
UK
Norway
US
118
David J. Hofmann NOAA Climate Monitoring and Diagnostics Laboratory US
Stacey M. Hollandsworth Applied Research Corporation US
James R. Holton University of Washington US
Lon L. Hood University of Arizona US
0ystein Hov Universitetet I Bergen Norway
Carleton J. Howard NOAA Aeronomy Laboratory US
Robert D. Hudson University of Maryland US
D. Hufford Environmental Protection Agency US
Linda Hunt NASA Langley Research Center US
Abdel M. Ibrahim Egyptian Meteorological Authority Egypt
Mohammad Ilyas University of Science Malaysia Malaysia
Ivar S.A. Isaksen Universitetet I Oslo Norway
Tomoyuki Ito Japan Meteorological Agency Japan
Charles H. Jackman NASA Goddard Space Flight Center US
Daniel J. Jacob Harvard University US
Colin E. Johiuon UK Meteorological Office/AEA Technology UK
Harold S. Johnston University of California at Berkeley US
Paul V. Johnston National Institute of Water & Atmospheric Research New Zealand
Roderic L. Jones University of Cambridge UK
Torben S. j0rgensen Danish Meteorological Institute Deamark
Maria Kanakidou Centre National de la Recherche Scientifique France
Igor L. Karol A.I. Voeikov Main Geophysical Observatory Russia
Prasad Kasibhatla Georgia Institute of Technology US
Jack A. Kaye NASA Goddard Space Right Center US
Hennie Kelder Koninklijk Nederlands Meteorologisch Instituut The Netheriands
James B. Kerr Atmospheric Environment Service Canada
M.A.K. Khalil Oregon Graduate Institute of Science and Technology US
Vyacheslav Khattatov Central Aerological Observatory Russia
Jeffrey T. Kiehl National Center for Atmospheric Research US
Stefan Kinne NASA Ames Research Center Germany
D. Kinnison Lawrence Livermore National Laboratory US
Volker Kirchhoff Instituto Nacional de Pesquisas Espaciais Brazil
Malcolm K.W. Ko Atmospheric and Environmental Research, Inc. US
Ulf K6hler Deutscher Wetterdienst Germany
Walter D. Komhyr NOAA Climate Monitoring and Diagnostics Laboratory US
Yutaka Kondo Nagoya University Japan
Janusz W. Krzyicin Polish Academy of Sciences Poland
Antti Kulmala Worid Meteorological Organization Switzeriand
Michael J. Kurylo NASA Headquarters/NIST US
Karin Labitzke Freie UniversitSt Beriin Germany
Murari Lai Indian Institute of Technology India
K.S. Law University of Cambridge UK
G. LeBras Centre National de la Recherche Scientifique France
Yuan-Pern Lee National Tsing Hua University Taiwan
Franck Lefinm Mitfo France, Centre National de Recherches M<tforologiques France
Jos Leiieveld Wageningen University The Netherlands
Robert Lesclaux University de Bordeaux 1 France
119
Joel S. Levine
Joel Levy
J. Ben Liley
Peter Liss
David H. Lister
Zenobia Litynska
Shaw C. Liu
Jennifer A. Logan
Nicole Louisnard
Pak Sum Low
Daniel Lubin
Sasha Madronich
Jen7 Mahlman
Gloria L. Manney
Huiting Mao
W. Andrew Matthews
Konrad Mauersberger
Archie McCulloch
Mack McFarland
Michael E. Mclntyre
Richard L. McKenzie
Richard D. McPeters
Gerard Migie
Paulette Middleton
Alvin J. Miller
Igor Mokhov
Mario Molina
Geert K. Moortgat
Hideaki Nakane
Paul A. Newman
Paul C. Novelli
Samuel J. Oltmans
Alan O'Neill
Michael Oppenheimer
S. Palenni
Ken Patten
Juan Carlos Pelaez
Stuart A. Penkett
Joyce Penner
Thomas Peter
Leon F. Phillips
Ken Pickering
R. Bradley Pierce
S. Pinnock
Michel Pirre
Giovanni Pitari
Walter G. Planet
NASA Langley Research Center US
NOAA Office of Global Programs US
National Insitutute of Water & Atmospheric Research New Zealand
University of East Anglia UK
Defence Research Agency UK
Centre of Aerology Poland
NOAA Aeronomy Laboratory US
Harvard University US
Office National d'Etudes et de Recherches A6rospatiales France
United Nations Environment Programme Kenya
University of California at San Diego US
National Center for Atmospheric Research US
NOAA Geophysical Fluid Dynamics Laboratory US
California Institute of Technology/Jet Propulsion Laboratory US
State University of New York at Albany/ASRC US
National Institute of Water & Atmospheric Research New Zealand
Max-Planck-Institut fiir Kemphysik Germany
ICI Chemicals and Polymers Limited UK
E.I. DuPont de Nemours and Company US
University of Cambridge UK
National Institute of Water & Atmospheric Research New Zealand
NASA Goddard Space Flight Center US
Centre National de la Recherche Scientifique France
Science and Policy Associates US
NOAA National Meteorological Center US
Institute of Atmospheric Physics Russia
Massachusetts Institute of Technology US
Max-Planck-Institute fiir Chemie Germany
National Institute for Environmental Studies Japan
NASA Goddard Space Flight Center US
University of Colorado US
NOAA Climate Monitoring and Diagnostics Laboratory US
University of Reading UK
Environmental Defense Fund US
Universita' degU Studi-l'Aquila Italy
Lawrence Livermore National Laboratory US
Instituto de Meieorologia Cuba
University of East Anglia UK
Lawrence Livermore National Laboratory US
Max-Planck-Institut fUr Chemie Germany
University of Canterbury New Zealand
NASA Goddard Space Flight Center US
NASA Langley Research Center US
University of Reading UK
Centre National de la Recherche Scientifique France
Universita' degli Studi-l'Aquila Italy
NOAA National Environmental Satellite, Data and Information Service US
33
120
R. Alan Plumb
Jean-Pierre Pommereau
Lamom R. Poole
Michael J. Prather
Margarita Pr^ndez
Ronald G. Prinn
Joseph M. Piospero
John A. Pyle
Lian Xiong Qiu
Richard Ramaroson
V. Ramaswamy
William Randel
Philip J. Rasch
A.R. Ravishankara
William S. Reeburgh
C.E. Reeves
J. Richardson
Brian A. Ridley
David Rind
Curtis P. Rinsland
Aidan E. Roche
Michael O. Rodgers
Henning Rodhe
Jose M. Rodriguez
M. Roemer
Franz Rohrer
Richard B. Rood
F. Sherwood Rowland
Colin E. Roy
Jocben Rudolph
James M. Russell ID
Nelson Sabogal
Karen Sage
Ross Salawitch
Eugenio Sanhueza
K.M. Sarma
Toru Sasaki
Sue M. Schauffler
Hans Eckhait Scheel
Ulrich Schmidt
Rainer Schmitt
Ulrich Schumann
M.D. Schwarzkopf
Gunther Seckmeyer
Jonathan D. Shanklin
Keith P Shine
H.W. Sidebottom
Massachusetts Institute of Technology US
Centre National de la Recherche Scientifique France
NASA Langley Research Center US
University of California at Irvine US
Universidad de Chile Chile
Massachusetts Institute of Technology US
University of Florida US
University of Cambridge UK
Academia Sinica China
CWfice National d'Etudes et de Recherches A^rospatiales France
NOAA Geophysical Fluid Dynamics Laboratory/Princeton University US
National Center for Atmospheric Research US
National Center for Atmospheric Research US
NOAA Aeronomy Laboratory US
University of California at Irvine US
University of East Anglia UK
NASA Langley Research Center US
National Center for Atmospheric Research US
NASA Goddard Institute for Space Studies US
NASA Langley Research Center US
Lockheed Corporation US
Georgia Institute of Technology US
Stockholm University Sweden
Atmospheric and Enviroiunental Research, Inc. US
TNO Institute of Environmental Sciences The Netheriands
Forschungszentrum JUlich Germany
NASA Goddard Space Flight Center US
University of California at Irvine US
Australian Radiation Laboratory Australia
Forschungszentrum JUlich Germany
NASA Langley Research Center US
United Nations Environment Prdgramme Kenya
NASA Langley Research Center US
Harvard University US
Instituto Venezolano de Investigaciones Cientificas Venezuela
United Nations Environment Programme Kenya
Meteorological Research Institute Japan
National Center for Atmospheric Research US
Fraunhofer Institut ftir Atmospharische Umweltforschung Germany
Forschungszentrum JUlich Germany
Meteorologie Consult Germany
DLR Institut fUr Physik der Atmosphare Germany
NOAA Geophysical Fluid Dynamics Laboratory US
Fraunhofer Institute for Atmospheric Environment Germany
British Antarctic Survey UK
University of Reading UK
University College Dublin Ireland
34
121
p. Simmonds University of Bristol UK
Paul C. Simon Institut d'Aeronomie Spatiale de Belgique Belgium
Hanwant B. Singh NASA Ames Research Center US
Paula Skfivinkovi Czech Hydrometeorological Institute Czech Republic
Herman Smit Forschungszentrum Jiilich Germany
Susan Solomon NOAA Aeronomy Laboratory US
Johannes Staehelin Eidgenossische Technische Hochschule Zurich Switzeriand
Knut Stamnes University of Alaska US
L Paul Steele CSIRO Division of Atmospheric Research Australia
Leopoldo Stefanutti Instituto di Riccrea suUe Onde Elettromagnetiche del CNR Italy
Richard S. Stolarski NASA Goddard Space Flight Center US
Frode Stordal Norsk Institutt for Luftforskning Norway
A. Strand University of Bergen Norway
B.H. Subbaraya Physical Research Laboratory India
Nien-Dak Sze Atmospheric and Environmental Research, Inc. US
Anne M. Thompson NASA Goddard Space Flight Center US
Xue X. Tie National Center for Atmospheric Research US
Margaret A. Tolberl University of Colorado US
Darin W. Toohey University of California at Irvine US
RalfToumi University of Cambridge UK
Michael Trainer NOAA Aeronomy Laboratory US
Charles R. Trepte NASA Langley Research Center US
Adrian Tuck NOAA Aeronomy Laboratory US
R. Van Dorland Koninklijk Nederlands Meteorologisch Instimut The Netheriands
Karel Vanicek Czech Hydrometeorological Institute Czech Republic
Geraint Vaughan University of Wales UK
Guido Visconti Universita' degli Studi-l'Aquila Italy
Andreas Volz-Thomas Forschungszentrum Jiilich Germany
Andreas Wahner Forschungszentrum Jiilich Germany
Wei-Chyung Wang State University of New York at Albany/ASRC US
David I. Wardle Atmospheric Environment Service Canada
David A. Warrilow UK Department of the Environment UK
Joe W. Waters California Institute of Technology/Jet Propulsion Laboratory US
Robert T. Watson Office of Science and Technology Policy US
E.C. Weatherhead NOAA Air Resources Laboratory US
Christopher R. Webster California Institute of Technology/Jet Propulsion Laboratory US
D. Weisenstein Atmospheric and Environmental Research, Inc. US
Ray F. Weiss Scripps Institution of Oceanography US
Paul Wennberg Harvard University US
Howard Wesoky National Aeronautics and Space Administration US
Thomas M.L. Wigley University Corporation for Atmospheric Research US
Oliver Wild University of Cambridge UK
Paul H. Wme Georgia Institute of Technology US
Peter Winkler Deutscher Wetterdienst Gennany
Steven C. Wofsy Harvard University US
Donald J. Wuebbles University of Illinois US
Vladimir Yushkov Central Aerological Observatory Russia
35
122
Ahmed Zand Tehran University Iran
Rudi J. Zander University of Liege Belgium
Joseph M. Zawodny NASA Langley Research Center US
Reinhard Zellner Universitat Gesamthochschule Essen Germany
Christos Zerefos Aristotle University of Thessaloniki Greece
Xiu Ji Zhou Academy of Meteorological Science China
Sponsoring Organizations Liaisons
Rumen D. Bojkov World Meteorological Organization Switzerland
K.M. Sarma United Nations Environment Programme Kenya
Daniel L. Albritton National Oceanic and Atmospheric Administration US
Michael J. Kurylo National Aeronautics and Space Administration US
Coordinating Editor
Christine A. Ennis NOAA Aeronomy Laboratory/CIRES US
Editorial Staff
Jeanne S. Waters NOAA Aeronomy Laboratory US
Publication Design and Layout
University of Colorado at Boulder Publications Service;
Elizabeth C. Johnston
Patricia L. Jensen
Andrew S. Knoedler
Conference Coordination and Documentation
Rumen D. Bojkov World Meteorological Organization Switzerland
Marie-Christine Charriite World Meteorological Organization France
Christine A. Ennis NOAA Aeronomy Laboratory/CIRES US
Jeanne S. Waters NOAA Aeronomy Laboratory US
Conference Support
Flo M. Ormond Birch and Davis Associates. Inc. US
Kathy A. Wolfe Computer Sciences Corporation US
36
123
Mr. ROHRABACHER. Dr. Albritton, I appreciate your fine testi-
mony today and the testimony we've heard.
I would suggest to our members that we go and vote and we
come immediately back after the vote and then we will hear the
next testimony and finish up the panel and then go into the ques-
tion period.
So we are in recess for ten minutes.
[Recess.]
Mr. ROHRABACHER. Ladies and gentlemen, we will move along.
We will proceed.
Dr. Watson, I want you to know that I am never concerned with
people with beards who aggressively make their case. [Laughter.]
Dr. Baliunas.
STATEMENT OF DR. SALLIE BALIUNAS, SENIOR SCIENTIST,
THE GEORGE C. MARSHALL INSTITUTE, WASHINGTON, DC
Dr. Baliunas. Thank you. Mr. Chairman and Members of the
Committee, I am a research astrophysicist. The following statement
is my personal view of the technical issues and does not represent
any institutional position.
The following is drawn from the peer-reviewed literature and
from the WMO reports.
Chart 1 on the easel — thank you — shows ozone fluctuations be-
tween 1957 and 1991 and these data are the northern hemisphere
ozone measurements from ground-base stations.
The ozone decrease over most of the world that is everywhere but
the Arctic and Antarctic has been stated as roughly three-tenths
percent per year between 1978-79 and 1994.
However, note three aspects of the ozone record.
First, accurately subtracting the large natural effects is difficult.
And, two, selecting starting points for the analysis over relatively
short records affects the outcome.
And three, plotting the chart on this kind of scale magnifies very
small changes.
Now because they cover a longer interval of time than the sat-
ellite data, these data more clearly reveal the extent of natural var-
iability. The record also indicates the level of natural variability be-
fore the 1970s, before any substantial anthropogenic impact on
ozone.
Now ozone levels change by a large amount every year between
spring and fall. Over Washington, D.C., ozone varies annually by
25 percent, some 80 times greater than the stated anthropogenic
decline. An average season has been subtracted from the data in
Chart 1, leaving other natural factors — for example, changes in the
sun's ultra-violet output or changes in the upper atmosphere wind
patterns of the earth, and any other trends.
Additional factors which are not currently corrected in records
may also exist. For example, decades-long shifts in meteorological
patterns.
Now the trends of ozone decline are usually established for two
starting points— 1970 and 1978 or 1979.
In the records shown in Chart 1, 1970 is the year of maximum
ozone level for the entire 34-year record, and 1978-79 is a minor
peak in the record.
124
Mr. RoHRABACHER. Excuse me for interrupting your testimony
here.
So you are saying that the year that is being used to judge all
the rest of the years on the amount of ozone was one of the highest
levels of ozone.
Is that correct?
Dr. Baliunas. Look on the chart. The very highest peak there —
maybe Debbie could point to the year 1970, and follow it up to the
top, the very highest peak in this 34-year record. A minor peak of
1978-79, fortuitously, when the satellites happened to be launched,
or coincidentally.
Mr. ROHRABACHER. Okay. And you're suggesting that that skews
the analysis?
Dr. Baliunas. That choosing those end-points in a very short
record, if one does not understand all the physical causes of ozone
change, does tend to skew the records, indeed.
Mr. ROHRABACHER. Thank you.
Dr. Baliunas. And the fact that the observed trends depends on
the selection of end points means that the trend has some uncer-
tainty and is not reliably determined.
Finally, Chart 1 shows the ozone fluctuations of a few percent on
a greatly magnified scale. However, the zero point on the scale is
missing. The total amount of ozone and its variations are shown in
Chart 2.
These are the exact same data as in Chart 1 and show the ozone
fluctuations in perspective, and again, the seasonal data, the large
seasonal data, are missing.
Now as for the accelerated phase-outs, the observational evidence
casts doubt on a substantial rapid thinning of ozone over most
Mr. ROHRABACHER. Excuse me, again. Can you tell us what you
think the significance of that chart is?
Dr. Baliunas. The first chart shows that the small changes have
been magnified on the scale. This chart shows the entire column
of ozone above our heads.
Mr. ROHRABACHER. And your conclusion from that is? I'm not
going to put words in your mouth. I just want to know what you
conclude because I think I know what you conclude.
Dr. Baliunas. This is what the total amount of ozone looks like.
One can draw one's own conclusion about the level of variability of
several tenths percent per year, and determining that.
Mr. ROHRABACHER. It doesn't look like there's much variation.
Dr. Baliunas. It is difficult to see on this scale.
Mr. ROHRABACHER. Thank you.
Mr. Ehlers. Mr. Chairman, may I also ask a clarification on the
chart?
Mr. ROHRABACHER. Yes. Certainly.
Mr. Ehlers. You said that this chart was the same as the pre-
vious one, except you're including the whole scale. But wasn't the
first one percent change rather than
Dr. Baliunas. That's right, rather than the entire column.
Mr. Ehlers. Now you don't have units on the first one. Are those
percentage points? They're not Dobson units.
Correct?
125
Dr. Baliunas. That's right. The average Dobson level on the
other one is slightly over 300. You can tell by looking at this chart,
by looking at the mean level there, zero.
Mr. Ehlers. Right. But I'm just clarifying.
Dr. Baliunas. Yes. The other chart is percent change from the
average.
Mr. Ehlers. And where it says minus two, it means minus two
percent?
Dr. Baliunas. Minus two percent.
Mr. Ehlers. From the average.
Dr. Baliunas. Right.
Mr. Ehlers. Thank you.
Mr. Olver. Mr. Chairman?
Mr. Rohrabacher. Yes.
Mr. Olver. As long as we're butting in here to clarify charts,
may I do a little bit of that, too?
Mr. Rohrabacher. That's absolutely fine, yes, sir.
Mr. Olver. Dr. Baliunas, you just said — I think I heard you said
a couple of times, the total amount of ozone.
When you say the total amount of ozone, is that meant to mean
the total amount of ozone in the atmosphere integrated over all de-
grees?
Dr. Baliunas. The Dobson unit is a column, one centimeter
square, to be specific, above the ground. This is averaged over the
northern hemisphere of ground station.
Mr. Olver. The northern hemisphere.
Dr. Baliunas. Northern hemisphere. It excludes the Arctic only
from 30 degrees to 60 degrees north.
Mr. Olver. So the data that you're talking about in this is an
integrated set of columns from over the northern hemisphere
Dr. Baliunas. From ground stations. From 30 to 60 degrees
north, yes.
Mr. Olver. Thirty to 60 degrees.
Dr. Baliunas. That's right.
Mr. Olver. Only in the northern temperate zone.
Dr. Baliunas. That's right.
Mr. Olver. Okay.
Dr. Baliunas. This would cover — this is land-based stations in
North America.
Mr. Olver. Are these data in your —
Dr. Baliunas. These are mentioned in the WMO report. They
are included in my testimony.
Mr. Olver. It's included in your testimony.
Dr. Baliunas. They are not my research. It's peer-reviewed lit-
erature, again.
Mr. Olver. But just to make sure I understand. This is just the
northern hemisphere.
Dr. Baliunas. Right. Ground-base data, no ocean coverage.
Mr. Olver. Could your aide show the previous chart again? It
was on very briefly as I was coming back in, so that I might see.
Dr. Baliunas. That's the percent change from that mean.
Mr. Olver. In that northern temperate zone.
Dr. Baliunas. In that same, right, northern hemisphere.
Mr. Olver. Thirty to 60 degrees.
126
Dr. Baliunas. Right. And these two charts are included in the
testimony.
Well, indeed, based on these small trends, the 1994 world mete-
orological executive summary estimates the cumulative ozone im-
pact loss in the next 50 years if all the CFCs currently contained
in refrigerators, air conditioners, et cetera, were released.
Since most of the CFCs are already in the atmosphere, prevent-
ing the release of CFCs in existing equipment would have little ef-
fect.
In fact, it would avoid an additional maximum ultra-violet-B ex-
posure equivalent to a move 1,000 yards closer to the equator.
Now the penalty for a four-year delay in the phase-out, what
would the delay of setting back the manufacturing date for CFCs
to the original year 2000 from 1996, cost in added UV-B exposure?
Similarly, assume the maximum future loss of 1.5 percent as
given in the WMO 1994 report for the northern mid-latitudes in
summer and fall, and assume that loss, that maximum loss, is sus-
tained for four more years.
The effect of that four-year delay would be equivalent to moving
20 miles closer to the equator for four years. Such small increases
in UV-B are hardly significant when compared to the natural fluc-
tuations in UV-B. For example, 50 percent seasonal changes.
Given the background of large natural fluctuations, such small
increases in UV-B also cannot be reliably extrapolated to yield a
small risk.
Mr. ROHRABACHER. Excuse me, again. I'm sorry for interrupting.
You say the seasonal changes. When is the season that is the
maximum UV-Bs?
Dr. Baliunas. Spring, summer, fall.
Mr. ROHRABACHER. That's the maximum time of exposure, when
we have exposure for human beings?
Dr. Baliunas. The maximum — let me get this exactly right.
Over Washington, D.C., ozone varies 25 percent.
Mr. ROHRABACHER. Right.
Dr. Baliunas. And it drops from the spring to the fall and then
recovers the following spring.
Mr. ROHRABACHER. Okay. Now, let me put it this way, in another
way.
The ozone layer is thickest in the winter or in summer months?
Dr. Baliunas. It is thickest in the — ozone levels drop in the
spring. So it's thickest towards the spring in the northern hemi-
sphere and drops in the fall.
Mr. ROHRABACHER. Okay. You can continue.
Dr. Baliunas. And, of course, the sun is changing at a slightly
different angle. So the amount of UV-B exposure is maximum usu-
ally in the late spring, early summer.
Mr. ROHRABACHER. Okay. Go right ahead.
127
Dr. Baliunas. I'm finished. My last sentence, just to reiterate —
the effect of the four-year delay would be equivalent to moving 20
miles closer to the equator for four years. Such small increases in
UV-B are not significant compared to the natural variations of 50
percent at the latitude of Washington, D.C., and given this large
backdrop, can't be extrapolated to meaningful levels of risk.
Thus, the delay of four years would entail no significant risk to
public health.
[The complete prepared statement of Dr. Baliunas follows:]
128
Ozone Variations and Accelerated Phaseout of CFCs
U.S. House of Representatives SubcsmSfittee on Energy and Environment
5iM>bCT2io/t9e5
Sallie Balinnas \
I am a research astrophysicist and Chair of the Science Advisory Board of the George C
Marshall Institute, a nonpartisan science and public policy research group. The following
statement is my personal view of the technical issues and docs not represent any institutional
position.
The accelerated phaseout of some stratospheric-ozone-depleting substances (SODS),
moved from 2000 to 1996, arose partly from a 1992 prediction of severe ozone loss over North
America. That prediction of severe loss is nov*' knovm to be incorrect Two topics will be
reviewed to show why tfie accelerated phaseout mi^t be reconsidered:
1. Global Ozone Chai^;e«
The ozone decrease over the rest of the world — that is, everywhere but in the Arctic
and Antarctic — has been stated as rougtily three-tenths of a percent per year between 1978-
1979 (when satellites were launched to make the first global ozone measurements)) and 1991
(before the eruption of Mt Pinatubo, which complicates the interpretation of tiw ozone record.
There are two major difficulties in the analysis of the ozone record which affect the
determination of a trend of a few tenths per cent per year: (1) accurately subtracting the nattiral
effects; and (2) selecting starting points for ti^e analysis in relatively short records.
Qiazt 1, showing the ozone fluctuations between 1957 and 1991 (prior to the eruption of
Mt Pinatubo), underecores the difficulties involved in determining a trend of a few tenths
percent per year: These data are the Northern Hemisphere (latitudes 30 to 60 degrees N) ozone
measurements from ground-based stations (Krzyscin 1994). Because they cover a longer
interval of time than the satellite data, they more dearly reveal the extent of natural variability,
and thus the difficulty of determining the SODS<aused trends. The record is also of interest
because it indicates the level of natural variability before the 1970s, and before the significant
buildup of SODS in the atmosphere and thtts any substantial anthropogenic impact on ozone.
The first diffimlty in determining a trend as small as 0.3% per year is the fact fiiat ozone
levels vary ruiturally by large amoimts. For example, ozone levels drop by a larg^ amount
every year between spring and fall (in the Nortiiem Hemisphere) and tficn recover. Over
Washington, DC, ozone varies annually by 25%, some 80 times greater than the stated
anthropogenic decline.
Ozone also varies because of other natural factors, including changes in the upper
atmosphere wind patterns of the earth (the quasi-biennial oscillation, or QBO, which introduces
ozone fluctuations over periods of 2-3 years), and the sim's xdtravioJet output, which varies
every 11 years. Additional factors which are not corrected in the records may exist, for
example, decades-long shift in meteorological patterns (Komhyr et al. 1991).
Because the magnitudes of these natural effects are so large, they must be accurately
knovwi before the anthropogenic trend can be deduced firom the data. One of the important
factors contributing to dUs natural variability is changes in the sun's ultraviolet flux, which
catise the creation and dissociation of ozone. But large variations in the stm's ultraviolet output
are known to occur and are unpredictable. Furdiermore, tiiey have not been measured
accurately even for one solar cycle. Instead, proxies are used to estimate the ultraviolet flux
changes, for example, the 10.7 cm radio flux. NASA-Goddard researchers (Herman et al. 1991)
found that ozone increased from 1978 - 1991 after they subtracted from the satellite ozone data
129
the known influences as well as the proxy of tfie solar effect. That increase is an error that
means that the estimate of the solar contribution by proxy is uncertain.
Fiirther evidence of the difficulty in subtracting the effects of solar variability by proxy
can be seen in the earKer ozone measuicments (Chart 1). In 1957 the most intense peak in the
entire four-century span of sunspot observations was recorded. That highest of sunspot peaks
should have produced the highest ultraviolet output from Ae stm, and therefore, a very hi^
ozone peak. Yet the ozone from tiie Northern Hemisphere shown in Chart 1 was very low in
the late 1950s - roughly as low as at present If the proxy method were used to estimate the
effect of the sun on ozone in 1957-58, the very high ultraviolet flux expected for the sun would
lead to a substantial reduction in the corrected ozorw levels. The corrected 1957-58 levels would
appear even lower than they are in the chart. This result reveals both the uncertainty of the
pro5<y method and the large range of natural variability.
Two additional features to note in this record are:
(i) The trends in ozone decUne in the 1994 WMO report are estimated for two starting
points: 1970 and 1978-79 (the latter is the start of the global ozone records measured by
satellites). But trend analyses based on relatively short tlrrve intervals can be skewed by the
endpoints choeen. In fact, in the case of the Northern Hemisphere data shown, 197D is a year of
maximum ozone abundance for tiie entire 34-year record, and 1979 is a minor peak of ozone in
the record. So choosing 1970 or 1978-79 as tiSe starting point creates the maximum possible
downward trends in ozoi\e since Sien. The selection of other starting points, for example, 1976
or 1957, would indicate no significant downward trend since ther\. The fact that the inferred
trend depends entirely on the selection of the endpoints meai\s ftat the trend has not been
reliably detemuned.
(ii) Plotting the data in tiiis way emphasizes very small changes in ozone. Chart 1
shows the ozone fluctuation of a few percent on a greatly magnified scale, after the average
seasonal fluctuation has been subtracted. However, the zero-point of the scale is missing. The
total amount of ozone and its variations are shown in Chart 2. These are the same data as m Chart
1. On this scale, the fluctuations in ozone are seen to be insignificant.
A longer ozone record comes from Tromso, Norway (Henriksen et aL 1994). It covers a
very limited geographical region, but spans some 50 years, from 1935 to 1989. Although these
measurements are less precise than the satellite measurements, they give a better indication of
natural variability because of the greater lengti\ of the record. This 50-ye» record shows large,
natural fluctuations over Tromso. For example, ozone dropped 15% over tiiree years in ttie
early 1940s. In the early 1960s, the ozone was roughly 10% lower than today. All these
fluctuations occurred prior to widespread use of SODS, and must be natur^^L
2. Uhniviolet-B
Instead of increasing, UV-B measured at eight stations either decreased or did not
change at ground level between 1974 and 1965 (Scotto et al. 1988). A recent recalibration of
those data by NOAA researchers (DeLuisi et al., 1995, private communication) yields a
tentative, small positive trend, but only for dear sky conditions, with no significant, increasing
trend for all-«ky data. A sustained effort of UV-B monitoring from 1975-1990 at a Smithsonian
laboratory in Maryland (Correll et al. 1992) shows that UV-B dosage dropped 2D% there
(latitude 40N) between 1979 and 1990, when ozone dechrwd about 3-4% .
Toronto researchers (Kerr and McElroy 1993) began a high-quality UV-B measuring
program in 1989. Those data, properly reanalyzed by Michaels et aL (1994), aiul recent
unpublished updates iiKhided in the 1994 WMO report, also show no significant increasing
trend in UV-B.
130
The Executive Summary of the 1994 WMO report concludes: "Uncertainties in
calibration, influence of tropospheric pollution, and difficulties in interpreting data from broad-
band instruments continue to preclude the unequivocal identification of long-term trends^ (p.
xv)"
As for media reports of eye and sidn diseases increasing in Chile during times of ozone
declines and UV-B increases related to the Antarctic polar vortex, a team of Johns Hopkins
physicians and researchers (Schein 1995) foimd "no increase in ... conditions attributable to UV-
B exposure ... for periods of known ozone depletion compared with control periods." Those
researchers note that the extra UV-B exposure on a few days resulted only in a 1% increase in
annual UV-B exposure.
Coftdtisions
The observational evidence casts doubt on (a) a substantia! thinning of ozone over most
of the world, and (b) iricreasing trends in UV-B radiation. The accelerated phaseouts, such as
the 1992 decision to end U.S. production of some SODS at the end of this year instead of 1999,
occurred partly in response to theoretical predictioi« made in 1992 of severe ozone depletion
for the high latitudes of North America. The magnitude and impact of that prediction are now
seen to have been greatly exaggerated, [n fact, the 1994 WMO report (p. 3.29) says, "In the
Arctic, ozone increases are found in both 1992 and 1993..."
Some replacement coolants are posited as strong agents of global waurming, and have
entered the international negotiatior\s on limits to greenhouse gases. Current policy discussions
to eliminate from use those replncement chemicals threaten to create another series of phaseouts
to some yet as undefined substitutes.
According to the WMO 1994 Executive Summary, eliminating all emissions of methyl
bromide from agricultural, structural and industrial use in 2001 would alleviate some of the
cumulative ozone loss over the next 50 years. Assuming the maximum theoretical UV-B
increase from the cumulative loss of ozone, how much additional UV-B exposure wiD be
averted by this proposed elimination of methyl bromide? Since UV-B strengthens toward the
equator, the maximum projected UV-B dosage avoided is equivalent to a move less than three
miies closer to tiw equator.
The 1994 WMO Executive Summary also estimates the ciunulative ozone loss in the next
50 years if all CFCs currently contained in refrigerators, air conditioners, etc, were released.
Since most of the CFCs are already in the atmosphere, preventing the release of CFCs in
existing equipment would have little effect. In fact, it would avoid an additional maximum UV-
B exposure equivalent to a move 1000 yards closer to the equator for 50 years.
Peaalfy for a 4-year delay in SODS pha5«out
What would a delay of 4 years — setting the date of the manufacturing ban for CFCs
like CFC-11 and CFC-12 back to tiie original year 2000 from 1996 - cost in added UV-B
exposure? Assume that the maximum future loss of 1.5%, as given in the WMO 1994 Executive
Summary for Northern midlatitudes in summer and fall, is sustained for 4 more years. The
efiect of the 4-ycar delay would be equivalent to moving less th/m 20 miles closer to Ae e<{uator
for 4 years. Such small increases in UV-B are hardly sigruficant compared to the natural
fluctuations in UV-6, for example, 50% seasonal changes at the latitude of Washington, EXZ.
Thus, the delay woxild entail no significant risk to public health.
131
132
133
Mr. ROHRABACHER. Dr. Setlow, we'd ask you to testify now. And
then right after your testimony, we will then break for the vote and
come back for the final witness, and then for questions for the
whole panel.
I think that's probably the best way we should go about it.
Dr. Setlow.
STATEMENT OF DR. RICHARD SETLOW, ASSOCIATE DIRECTOR,
LIFE SCIENCES, BROOKHAVEN NATIONAL LABORATORY,
UPTON, NY
Dr. Setlow. Thank you, Mr. Chairman.
I'm going to speak about biology in two aspects. One is to tell you
a fish story, and I'm sure in Congress, you're very familiar with
such things.
The second is to tell you something about the uncertainties in
our knowledge. You've just been hearing about the uncertainties in
our physical knowledge. I assure you that the uncertainties in our
biological knowledge are much, much greater, probably ten- to a
hundred-fold greater.
We don't know how to extrapolate or predict what the biological
effects might be of ozone depletion and ultra-violet increases at the
surface of the earth among humans, plants, animals, eco-systems
and so on.
I just want to call your attention to the fact that in a rational
world, the funding should be proportional to the uncertainty. If
we're uncertain about something, we should put more money into
finding that out than if we're not.
In the case of the ozone depletion story, the funding has been in-
versely proportional to the uncertainty. The greater the uncer-
tainty, the less the funding.
That is to say, biology has never received adequate funding to
solve the questions, the answers to which you need. And I will ex-
emplify this with a fish story and tell you a little bit about skin
cancer and melanoma.
You have to remember that cancer is a very complicated disease.
It involves many steps — initiation, progression, immune-surveil-
lance, and so on.
We don't know which is the rate-limiting step in environmental
carcinogenesis. Remember that.
I'm going to describe to you an experiment that tells you about
the initiation, the start of the process, by producing damage to
DNA, and we know that damage to DNA is important because indi-
viduals who are defective in the ability to repair DNA have skin
cancer prevalances 1000 or more fold greater than the normal.
But we don't know about the normal population. We know about
the repair-deficient population.
So what we really need is some knowledge about animal models.
Since we don't easily do experiments on people, we're not permitted
to do that, and we have to count on epidemiological data, and the
epidemiological data really are built upon a pre-conceived notion of
animal models, we must rely on animal models.
There is no good animal model at the moment that will tell us
what wavebands of ultra-violet give rise to melanoma.
134
I assume you all know that most skin cancer comes from sun-
light exposure. But which portions of sunlight is the question.
The only convenient model at the moment is a model using fish,
small tropical fish that have been bred to be very sensitive to mela-
noma induction, deliberately. So that a short exposure in the lab-
oratory of these little fish gives rise to the start of a melanoma that
is perceptible by a few months and can be scored. And in this way,
we measure the sensitivity as a function of wavelength, inducing
melanomas.
We find that the most sensitive wavelength is in the UV-B re-
gion of the spectrum. But that is not the whole story because we
have to worry about how much UV-B and UV-A is actually in nat-
ural sunlight. There's much more UV-A in sunlight than UV-B. So
what we're really interested in is the product of the two.
I have a table in my text which shows for nonmelanoma skin
cancer and for melanoma skin cancer, the values for UV-A and
UV-B, the sensitivities per unit energy, and how much of skin can-
cer on a mouse model for humans would give rise to nonmelanoma
skin cancer — about 95 percent, roughly speaking, of UV-B is the
important one.
In the case of melanomas, 90 percent of the effect would come
from UV-A.
Now when I say melanomas, you must remember, these are ex-
periments done with fish. Are you willing to extrapolate from fish
to humans? Well, I'm willing to extrapolate from fish to humans
because, after all, fish have DNA. They have melanocytes. They
have melanin. And they get melanomas.
Many people are not very happy about extrapolating this fish
story to humans, and so that's an uncertainty. The big uncertainty
lies not in the data on fish, but on whether it's valid to extrapolate.
This is a big biological problem.
Moreover, our experiments deal with the initiation, the first step
in cancer induction in these fish because they've been bred to be
sensitive to that.
What about all the other steps in humans — progression, immuno-
surveillance? How do they depend upon wavelength?
So the point I'm trying to make is that the cancer depends on
lots of steps about which we have limited knowledge. We know one
step very carefully for fish. We know some of these steps for mice
for nonmelanoma skin cancer.
My conclusion is that the large increase in skin cancer over the
years, especially melanoma, I should say, over the years, four to
five percent per year, well documented, good scientific, peer-re-
viewed data, arises obviously not from anything to do with ozone
depletion because melanoma has been increasing for 50 years.
It has to do with our lifestyles, how we go out in the sun, how
we apply sunscreens. Sunscreens screen out the UV-B. And those
of us that like to go out in the sun put them on and stay out for
a longer time and we get UV-A.
135
And so, hypothetically, this is the reason for the increase in
melanoma. It is our Ufestyle. It is not ozone depletion.
Whether you make the extrapolation, as I say, requires other
models and a lot more knowledge.
Thank you.
[The complete prepared statement of Dr. Setlow follows:]
136
Testimon^f Richard Setlow
f before the
United States^Housfr-ofl^epresentatives
Conmittee on Science
Subcommittee on Energy and Enviroranent
September 20. 1995
Sunlight and Malignant Melanoma:
Prediction of the Effects of Ozone
Depletion and Sunscreen Use
137
Sunlight and Malignant Helanooa: Predictions of the Effects
of Ozone Depletion and Sunscreen Use
Richard Setlow*
Brookhaven National Laboratory
Upton. New York 11973
Before discussing sunlight exposure and human skin cancer. I make a
few general philosophical remarks on the concerns of ozone depletion and
UV increases. The concerns are mostly biological --the effects on humans,
animals, plants, and terrestrial and aquatic ecosystems. The quantification
of these concerns involves the product of two different estimations: 1)
the increase in UVB for a given decrease in stratospheric ozone and 2) the
increase in biological effects for a given increase in UVB. The first is
estimated from physical and chemical measurements and theory and has uncer-
tainties of - 10-203;. The second depends on biological measurements and
theory and is uncertain, I am sorry to say, by a factor of 2-10, i.e.
lOO-l.OOOX. There is an impedance mismatch between the physicochemical and
the biological uncertainties. Even if we knew the physicochemical values with
great precision, we cannot now predict the biological effects with certainty.
It should be obvious to you that the funding- -the determiner of scientific
effort --should be proportional to the uncertainty. I regret that since the
1970s through the present the funding has been inverslv proportional to the
uncertainties, the greater the uncertainty, the less the funding. Thus,
for example, it is not clear which of the several steps in carcinogenesis- -
initiation, promotion/progression, immunological surveillance, metastasis- -is
the rate limiting step for skin cancer induction in normal humans. This is
especially the case for melanoma.
A recent article (Journal of the American Medical Association. August 9,
1995, page 445) indicates that there are "now an estimated 1 million new cases
of skin cancer each year in the United States." Skin cancer deaths number
- 9,000 per year of which 7,200 are due to malignant melanoma. Malignant
melanoma of the skin has been increasing A-SX per year for approximately 50
years- -obviously not the result of changing ozone. It is associated in a
complex way, compared to non-melanoma skin cancer, with exposure to sunlight
(Armstrong & Kricker, Melanoma Res. 3, 395-401 [1993]). It is more connnon
*I am a Sr. Biophysicist and the Associate Director for Life Sciences. I have
a Ph.D. in Physics from Yale University and have been working in the field of
biophysics and on the effects of ultraviolet radiations on molecules, viruses,
cells, and animals since the early 1950s. I was elected to the National
Academy of Sciences in 1973 and have served on numerous coiranittees dealing
with the effects of radiations. I was a member of the National Research
Council Climatic Impact Committee from 1972 until it issued its Report in
1975. I have been recognized nationally and internationally for my work.
My most recent research deals with an experimental model --fish- -that may
be used to determine the wavelengths effective in melanoma induction.
138
in fair skinned individuals and its prevalence is higher at low latitudes.
The fact that individuals deficient in repair of DNA damage have a melanoma
prevalence over 1,000 -fold greater than normal individuals is evidence that
sunlight -induced DNA damage is an initiating stimulus for melanoma. The
effects of DNA damage are ameliorated, in part, by human DNA repair systems,
systems that may be quantitatively more effective than in mouse or in fish.
Epidemiological evidence and data from experiments with mice indicate
that chronic exposure to UVB- -the shorter UV in sunlight that is absorbed
by DNA and is mostly screened out by stratospheric ozone- -is the most
effective spectral range for inducing non-melanoma skin cancer. Similar
data for malignant melanoma are not as clear, but they indicate that the
spectral regions not affected by ozone depletion- -presumably the longer
UVA wavelengths- -are important ones. At present, the only useful animal
model to measure the wavelengths effective in light-induced melanoma induction
is small backcross hybrid tropical fish, bred to be very sensitive to induc-
tion. (Several mammalian models are now being developed.) The biological
effect of UV depends upon the biological sensitivity in different spectral
regions, such as UVB and UVA. the amount of sunlight in these spectral regions
and how the biological response varies with the dose- -the dose-response rela-
tion. The latter is not really known for human melanoma induction. However,
the wavelength sensitivity for the initiation of melanoma is known from
experiments on fish. There is appreciable sensitivity for melanoma induction
in the UVA region. Because of the large amounts of UVA in sunlight, the UVA
in sunlight is the most effective spectral range for melanoma induction in
fish. Is it appropriate to extrapolate from fish to humans? I think so. but
there is no consensus yet. The wavelength sensitivities of the other steps
in carcinogenesis are not known although human epidemiological data seem to
indicate that UVB exposure is not of major importance (Magnus. Int. J. Cancer
47. 12-19 [1991]). A simple summary of our results is given in the following
table.
APPROXIMATE RELATIVE VALUES FOR SKIN CANCER
INDUCTION BY UVB AND BY UVA
Non- melanoma (mouse)
energy in
sunlight
X
sensitivity per ^
unit energy
^ sensitivity
to sunlight
UVB
UVA
1
50
1
0.001
1
0.05 1
95* from
UVB
Melanoma (fish)
UVB
UVA
1
50
1
0.2
1
>
10
90* from
UVA
139
The results on fish- -a fish story- -if extrapolated to humans indicate:
1) any ozone depletion and attendant UVB increase will have only a small
effect on melanoma induction, and 2) the use of sunscreens that principally
absorb UVB. so as to minimize sunburn, encourage individuals to spend more
time in the sun and so increase their UVA exposure and increase the risk of
melanoma initiation. A recent case-control epidemiological study indicates
that melanoma prevalence is higher among individuals using sunscreens than
those who do not (Int. J. Cancer 61, 749-755 [1995]).
A brief summary of our experimental results is given in a chapter in
a book entitled. Ozone - Sun - Cancer: Molecular and Cellular Mechanisms
Prevention Conference, published in 1995. A copy of the chapter is attached.
I would appreciate it if it were included in the record of my testimony.
140
FocuS
Ozone
Sun
Cancer
Molecular and cellular
mechanisms
Prevention
L. Dubertret, R. Santus, P. Morliere
editors
1995
IHlllll/llllll
LES EDITIONS
IMSBHiVl
141
Cancer of the melanocytic system
R.B. Setlow*
Most skin cancer among Caucasians is associated with exposure to sunlight
[1], and damages to cellular DNA are implicated as initiating events be-
cause repair-deficient individuals (xeroderma pigmentosum) are orders of
magnitude more susceptible than normal individuals. Within reasonably
homogenous populations, skin cancer increases toward low latitudes, but
this association does not indicate the wavelength regions involved in cancer
induction. At present, the only animal model suitable for determining the
wavelengths effective in melanoma induction are certain inter- and intra-
species hybrids of the small fish, Xiphophorus. Genetic evidence indicates
that the hybrids contain only one tumor suppressor gene and, therefore, are
very sensitive to cancer induction by single exposures to light [4]. I and my
colleagues [3] exposed 5-day old fish, in spectrophotometer cuvettes, to dif-
ferent monochromatic wavelengths and fluences. The fish were kept for two
months in tanks shielded with yellow plastic, so as to minimize the possibil-
ity of photoreactivation, and were scored at four months. The melanoma
prevalence increased with exposure to a maximum of ~ 0.5 (Fig. 4-1). The
fluence-response curves were fitted to surviving fraction = a + b (l-e'"^),
where a is the background prevalence with no exposure, b is the maximum
induced prevalence, k is the sensitivity parameter (the cross section for mel-
anoma induction), and E is the incident fluence. The value of k at 302 nm
was 0.05 mVJ giving a mean melanoma inducing exposure, for swimming
fish, of 200 J/m^, corresponding to 3.5 cyclobutane pyrimidine dimers per
Mbp of DNA in irradiated fish skin. At this wavelength the mean erythemal
dose for a stationary human is 400 J/m^ [2].
The sensitivities at the other wavelengths tested, relative to the value of
1.00 at 302 nm, are given in Fig. 4-2a, along with the action spectrum for
human erythema and the mid-summer sun's spectrum at 41°N latitude.
The melanoma sensitivity in the UVA^ region is orders of magnitude greater
* Biology Department, Brookhaven National Laboratory, Upton, New York 11973
USA.
142
Photocarcinogenesis anirnal models 127
• •
(a)
9*
O
3 "
r
6 oj-
«j-
01
1000 MOO •000 SOOe moo 7000
1000
MOO MOO
Fig. 4-1 Fluence response curves for melanoma induction in hybrid fish by
a) 405 nm, and b)313 nm. The errors are standard deviations. The background
level at 405 nm is less than at 313 nm. The latter experiment used fish maintained
in the ambient light of a shaded greenhouse. The former used fish maintened in
tanks screened, for two months, by yellow plastic. We interpret the difference as
indicating that visible light is effective in melanoma induction.
128 Ozone sun cancer
143
1 10^
(a)
Human Efythenu <j,
Pamsh. et al . 1982
■1
300 340 3«0
Wavdengtti (nm)
- (b)
A
Human "O
E(yni«na \ -
^(jVB— UVA «— vtsiWt
J I y L
260 300 340 380 420
Wavelength (run)
Fig. 4-2 a: Action spectra for melanoma induction and human erythema normal-
ized to 1.00 at 302 nm. Note the exponential sensitivity scale, b: The relative sun-
light effective dose versus wavelength.
than for erythema, and sunHght contains much more UVA than UV B. The
product of the sun's spectrum multipHed by the action spectrum is the rela-
tive sunhght dose as a function of wavelength (Fig. 4-2b). If the human ac-
tion spectrum were similar to the fish spectrum, UV B would contribute
only 5 to 10% of the melanoma inducing effect and 90 to 95% could be as-
cribed to UV A and visible. Hence, O3 depletion would have a negligible ef-
fect on melanoma incidence. The high sensitivity to UV A may be explained
by free radicals or other activated products formed in melanin which then
may affect cellular DNA. Since most sunscreens absorb much more UV B
than UVA [1]. Individuals who use UV B sunscreens and increase their ex-
posure time to the sun, would increase their UV A carcinogenesis dose. An
8-fold increase in exposure time by an individual using an SPF 8 UV B sun-
screen would result in a 5 to 6-fold increase in melanoma inducing dose.
Hence, the habits of sun exposure, especially the use of sunscreens, would
greatly increase the melanoma inducing dose and could be responsible for
the melanoma epidemic and exponential increase, 5% a year for 40 or more
years.
144
Photocarcinogenesis animal models liiy
This work was supported by the Office of Health and Environmental Research
of the U.S. Department of Energy.
Key-note references
1. DiFFEY BL: The need for sunscreens with broad spectrum protection. In Urbach
F (Ed.), Biological Responses to Ultraviolet A Radiation, Valdenmar Pub. Co. Over-
land Park, Kansas, 1992, pp. 321-328.
A careful examination of monochromatic protection factors and the relative expo-
sures as a function of wavelength when using different sunscreens.
2. Parrish JA, Jaenicke KF, Anderson RR: Erythema and melanogenesis action
spectra of normal human skin. Photochem Photobiol 1982 36: 187-191.
Data from 250 nm to 405 nm (see Fig. 4-2a). Note that the values of the ordinate
in Fig. 4-la of this reference are too large by a factor of 10.
3. Setlow RB, Grist E, Thompson K, Woodhead AD: Wavelengths effective in in-
duction of malignant melanoma. Proc Natl Acad Sci USA 1993 90: 6666-6670.
The fish model, described in ref 2, was used to determine the melanoma suscepti-
bility to single exposures to 302, 313, 365, 405, and 436 nm (see Fig. 4-2a).
4. Setlow RB, Woodhead AD, Grist E: Animal model for ultraviolet radiation-
induced melanoma: Platyfish-swordtail model. Proc Natl Acad Sci USA 1989 86:
8926-8926.
A description of useful animeil models, Xiphophorus maculatus xXiphophorus hel-
leri backcross hybrids that develop malignant melanomas within 4 months of expo-
sure to sunlamp radiation > 290 nm or > 304 nm delivered as one or 20 treatments.
Exposure of the fish to visible fluorescent light after UV reduces the tumor preva-
lence to background levels.
5. Urbach F: Ultraviolet radiation and. skin cancer. In Smith KC (Ed.), Topics in
Photomedicine, Plenum, New York, 1984, pp. 39-142.
A comprehensive review of the photobiology, epidemiology and clinical aspects of
non-melanoma and melanoma skin cancer throughout the world.
145
Mr. ROHRABACHER. Doctor, thank you very much. We're going to
break now and just go vote and come right back and proceed with
the testimony and then the questioning with the entire panel.
So this hearing is now in recess.
[Recess.]
Mr. RoHRABACHER. The hearing will come back to order and
move forward. As Members come in, we will permit them to partici-
pate. I'd like to thank all the witnesses so far. We're going to have
questions and answers of the entire panel after Dr. Kripke presents
her testimony. And then, we will break for lunch after the ques-
tioning of this panel and before we call the next panel.
So, Dr. Kripke.
STATEMENT OF DR. MARGARET L. KRIPKE, PROFESSOR AND
CHAIRMAN, DEPARTMENT OF IMMUNOLOGY, UNIVERSITY
OF TEXAS, M.D. ANDERSON CANCER CENTER, HOUSTON, TX
Dr. Kripke. Thank you, Mr. Chairman.
My name is Margaret Kripke and I am here as a scientist who
works in the area of health effects of UV-B radiation.
My research over the past 20 years or so has focused on the role
of UV-B radiation in both melanoma and non-melanoma skin can-
cer and on the effects on the immune system.
In addition, I currently serve on the United Nations Environ-
ment Programme Panel that reviews the health effects of ozone de-
pletion according to the Montreal Protocol. And much of my testi-
mony today is based on the panel's 1994 assessment, which rep-
resents the collective wisdom of scientists all over the world who
carry out research in this field.
And it is, if I may paraphrase, the conclusion of this document
that even a small increase in UV-B radiation present in sunlight
is likely to have important consequences for plant and animal life
on earth and will almost certainly jeopardize human health.
The best studied harmful effect of UV-B radiation on human
health is the induction of non-melanoma skin cancers, basal and
squamous cell carcinomas.
Now, as has been mentioned earlier, the incidence of these skin
cancers in the United States is already enormous. It's approaching
a million new cases per year. This number has been increasing
steadily over the past several decades.
And additional increases, beyond those already observed, will
certainly result from ozone depletion.
You also heard this morning that currently CFC phase-out sce-
narios predict that stratospheric ozone levels will reach a minimum
in the next few years and then will gradually return to baseline
levels by about the year 2050.
Well, what will that do to skin cancer incidence?
Because of the long latent period, the lag period from ultra-violet
exposure to skin cancer incidence, this means that the increase in
skin cancer incidence will be with us much longer than 2050.
In fact, it will probably only begin to peak in around the year
2050.
So the skin cancer increases due to increased ultra-violet radi-
ation are likely to be with us well into the next century and clear
to the end of the next century.
146
Chronic exposure to ultra-violet radiation also is associated with
several harmful effects on the eyes. The most important of these
is cataract, which causes blindness in about 17 million people
world-wide. And it is clear that the incidence of cataract will in-
crease if UV-B levels rise.
Now, what about melanoma skin cancers?
As you heard from Dr. Setlow, there is great uncertainty in the
wavelengths of ultra-violet light that contribute to melanoma.
These uncertainties preclude our ability to estimate the impact of
ozone depletion on this tjrpe of skin cancer at the present time.
It is very important to know what are the wavelengths of ultra-
violet light involved in melanoma skin cancer. If UV-B is the pre-
dominant wavelength, then the impact of ozone depletion can be
considerable.
If UV-A is the principal cause of melanoma, then the impact of
ozone depletion is much less.
But I will point out, based on Dr. Setlow's testimony, that the
effect is not zero.
There is some circumstantial evidence in humans for a causal
role of UV-B radiation in melanomas from past studies, but I think
there is newer data from molecular approaches to this problem that
promise to provide us with a more direct answer to this question.
Very recent molecular studies on human melanomas point to a
role for UV-B radiation in melanoma induction, but so far, they do
not point to a role for UV-A radiation.
Now although these findings are still preliminary and incom-
plete, they point very strongly toward a causal role of UV-B radi-
ation in the development of some melanomas in humans.
UV-B radiation also perturbs the body's immune system. Now
our immune system is what protects us against infectious diseases
and certain kinds of cancer. And so, an3rthing that could have an
impact on immune function has the potential to jeopardize human
health by increasing the incidence or the severity or the duration
of infectious diseases and certain kinds of cancers as well.
The ability of UV-B radiation to alter and to decrease the body's
immune function is well demonstrated in laboratory animal mod-
els. It has also been demonstrated in animal m.odels that ultra-vio-
let radiation decreases immunity to infectious agents, such as her-
pes virus, leishmania, mycobacterial infections, which cause leprosy
and tuberculosis, Candida, trichinosis, Lyme disease, the list goes
on.
In most of these disease models, immune responses to the infec-
tious organisms are diminished and the severity or duration of dis-
ease is increased.
There is now also substantial evidence that UV-B radiation can
alter and decrease immune function in humans, including one
study showing that the immune response to leprosy is decreased in
human skin exposed to UV radiation.
This study is one of the only ones available in humans that in-
vestigates the effect of ultra-violet radiation on the immune re-
sponse to an infectious organism.
But I think the message is very clear. Both the animal studies
and the limited data available in humans give us reason to believe
147
that increased UV-B radiation could increase the severity of some
infections in human populations.
Furthermore, skin pigmentation, which is protective against skin
cancer, does not provide much protection against the immuno-
suppressive effects of ultra-violet light in humans, suggesting that
the population at risk is very large and not limited to the light-
skinned individuals who are at risk for skin cancer.
Now because infectious diseases constitute an enormous public
health problem world-wide, any factor that has the potential to re-
duce immune defenses and increase the severity of infectious dis-
eases is likely to have a devastating impact on human health.
At the present time, however, not a single prediction about the
impact of ozone depletion on a single infectious disease in a single
geographic location in human beings is available.
And this is not because the problem is not important, but it is
because there is no information on which to base this type of an
assessment.
My last point is that, finally, UV-B radiation may also adversely
affect human health indirectly, by interfering with the food chain,
by means of its effects on crops, plants and marine organisms.
I think it is very ironic and very unfortunate that the two poten-
tial health consequences of ozone depletion that could have the
greatest impact on human health by affecting the food supply, by
affecting infectious diseases, which are in fact the two greatest
health problems in the world, are the two areas in which we have
the least amount of available relevant information.
Thank you, Mr. Chairman.
[The complete prepared statement of Dr. Kripke follows:]
148
HUMAN HEALTH EFFECTS OF ULTRAVIOLE T-B RADIATION
Kripke, Ph.D.
Vivian D>-Sinith-^hair in Immunology
Professor and Chairman, Depanmcnt of Immunology
The University of Texas M. D, Anderson Cancer Center
Houston, Texas
United States House of Representatives
Committee on Science
Subcommittee on Energy and Environment
Hearing on Accelerated Phaseout of
Stratospheric Ozone Depletion Substances
September 20, 1995
149
INTRODUCTION
My name is Margaret Kripke, and I am here today as a scientist
and expert in the area of health effects of UV-B radiation. My
research over the pasc 20 years has focused on the role of UV-B
radiation in both melanoma and nonmelanoma skin cancer and on
the effects of UV-B radiation on the immune system. In addition to
my personal research expertise in this field, in 1987, I chaired a
subcommittee of the U.S. EPA Science Advisory Board that reviewed
the EPA's document on the science behind the causes and effects of
stratospheric ozone depletion, and I currently serve on the United
Nations Environment Programme Panel that reviews the
environmental effects of ozone depiction every 4 years, in
accordance with Article 6 of the Montreal Protocol. Much of my
testimony today is based on the panel's 1994 assessment of the
available scientific information on ozone depletion (1), which
represents the collective wisdom and consensus of scientists all over
the world who carry out research in this field.
OVERVIEW
The amount of UV-B radiation in natural sL-nlight is dependent
on the concentration of ozone molecules in the atmosphere. Reducing
the ozone concentration would increase the amount of UV-B radiation
reaching the surface of the earth. Even a small increase in the
amount of UV-B radiation present in sunlight is likely to have
important consequences for plant and animal life on earth and will
almost certainly jeopardize human health. The best understood
harmful effects of UV-B radiation on human health arc its ability to
cause basal and squamous cell cancers of the skin and eye damage,
including cataract, which can lead to blindness. Sufficient
information is now available to permit quantitative estimates of the
impact of ozone depletion on nonmelanoma skin cancer and cataract.
150
UV-B radiaiion also contributes to the devciopmenl of
melanoma skin cancer and perturbs the body's immune system in
ways that can reduce immunity to infectious agents. These effects
are poorly understood, and therefore, the magnitude of the impact of
increased UV-B on these health problems cannot be estimated at the
present lime. UV-B radiaiion may also adversely affect human
health indirectly by interfering with the food chain. On a global
scale, the potential of UV-B radiation to increase the infectious
disease burden, cause blindness, and reduce the world's food supply
constitute the most important possible consequences of increased
UV-B radiation for the world's populations.
EFFECT OF UV-B RADIATION ON BASAL AND SQUAMOUS
CELL CANCERS OF THE SKIN
Most basal and squamous cell carcinomas of the skin occur on
the most heavily sun-exposed body sites of lighi-skinncd individuals,
and the incidence rates of these cancers increase with age. These
observations, coupled with years of laboratory studies of animal and
cell culture models, demonstrate that cumulative lifetime exposure to
solar UV-B radiation is the most important cause of these non-
melanoma skin cancers. The incidence of these .skin cancers in the
U.S. is already enormous and is approaching 1 million new cases per
year. The number has been increasing steadily over the past few
decade.s. and additional increases in the rate of non-melanoma skin
cancer development, above and beyond those already observed, will
result from ozone depiction. Current CFC phascout scenarios predict
that stratospheric ozone levels will reach a minimum around the
year 2000 and will gradually return to 1950 levels by the year 2050.
Because of the long latent period for the development of non-
melanoma skin cancers, however, this pattern of ozone depletion will
cause the incidence of skin cancer to continue to rise at least until the
year 2050 and probably beyond. The latest estimates indicate that
for a ]% reduction in ozone, the incidence of non-melanoma skin
cancer will increase by 2.0 + 0.5%. With approximately 1.25 million
new cases of skin cancer each year worldwide today, this means that
151
a sustained 10% decrease in average ozone concentraiion would lead
to 250,000 additional non-melanoma skin cancers each year.
EFFECTS OF UV-B RADIATION ON THE EYES
Chronic exposure of the eyes to UV-B radiation is associated
with several deleterious effects on vision. These effects are
independent of eye and skin color; thus, the population at risk is
very large. UV-B radiation contributes to the formation of cataract,
which causes blindness in 17 million people worldwide. It is
estimated that a 1% decrease in ozone concentration will increase the
incidence of cataract by around 0.5%; however, the exact number is
uncertain because the wavelengths of UV-B radiation involved are
not precisely defined. It is certain, however, that the incidence of
cataract will increase if ambient UV-B levels rise unless mitigating
behaviors are adopted. In countries where sunglasses and cataract
surgery are not readily available, the problem of blindness caused by
cataract will undoubtedly increase.
EFFECT OF UV-B RADIATION ON MELANOMA SKIN CANCER
Melanoma, a cancer of pigment producing cells, accounts for
only about 4% of skin cancer cases in the U.S., but it is responsible for
more than 60% of the deaths. Based on many epidemiological and
laboratory studies, it is now clear that exposure to solar UV radiation
is a major risk factor for human melanoma in light-skinned
populations. However, major uncertainties preclude our ability to
estimate the impact of ozone depiction on this type of skin cancer at
the present time. Fir.st. the role played by UV in melanoma
development is not well understood and is probably quite complex;
second, the dosc-rcsponsc (how melanoma incidence is related to the
amount and frequency of UV exposure) is not understood; third, the
exact waveband of UV involved in melanoma development (action
spectrum) has not been established.
The question of waveband is panicularly important because
wavelengths in the UV-A region of the spectrum (320-400 nm) will
152
5
be minimaUy affected by ozone depiction, whereas those in the UV-B
region (280-320 nm) will be strongly affected. There is some
circumstantial evidence for a causal role of UV-B, which has been
reviewed extensively in the past (1). However, molecular
approaches to this problem promise to provide a more direct answer
to this question. Recent molecular studies of human melanomas
point to a role for UV-B in melanoma induction, but do not provide
evidence of a role for UV-A (2). In one of these studies, a melanoma
susceptibility gene called MTS-1 was analyzed in 30 human
melanoma cell lines for the presence of UV-spccific mutations; 37%
of the melanomas had mutations in this gene, and 67% of the
mutations were of the types caused by UV-B. The most common
type of mutation caused by UV-A radiation (3) was not found among
31 mutations in MTS-1 analyzed in various studies to date. These
studies suggest that a minimum of 25% of melanomas may involve
UV-B exposure. The actual percentage may be much higher because
more than this one gene is likely to be involved in melanoma
development, and a direct alteration in DNA is only one of several
way.s in which UV-B can contribute to cancer induction. Although
these findings are still preliminary and incomplete, they point
toward a causal role of UV-B radiation in melanoma development in
humans.
EFFECTS OF UV-B RADIATION ON THE IMMUNE SYSTEM
The immune system is the body's main defense mechanism
against infectious diseases. In addition to providing protection
against bacterial, viral, fungal, and parasitic infections, the immune
system also protects against the development of certain types of
cancer, particularly those associated with cancer viruses and UV
radiation. Any impairment of immune function could jeopardize
health by increasing su.sceptibility to infectious diseases, increasing
the severity or duration of infections, or increasing the incidence of
certain cancers.
The immunosuppressive effects of UV-B radiation in laboratory
animals are well documented. Immune responses initiated or
153
elicited within UV-B-irradiated skin arc diminished, and
immunization through UV-B-irradia(cd skin can lead to a long-lasting
slate of unresponsiveness to the immunizing agent. With higher
doses of UV-B. immune responses initiated at unexposed sites may
also be suppressed. The.se findings led to concerns that immunity to
infectious diseases might also be compromised by UV irradiation,
resulting in an increase in the severity or incidence of certain
diseases. This possibility wa.*? borne out in a number of rodent
models of infectious diseases, including cutaneous herpesvirus
infection, leishmaniasis, mycobacterial infections similar to
tuberculosis and leprosy, candidiasis, trichinosis, AIDS, and Lyme
disease (borrcliosis). In all of these disease models, immune
responses to the infectious organism was diminished, and the
severity of the disease was increased. Only with one disease,
schistosomiasis, was no effect of UV irradiation found. Why
resistance to this particular disease is unaffected by UV-B irradiation
is unknown, which makes it impossible to predict which diseases will
be affected and which will not.
There is also substantial evidence that UV-B alters immune
function in humans by mechanisms similar to those described in the
rodent models, although much less information is available for
humans. The immune response to chemicals applied to UV-B-
irradiated human skin is reduced, and long-lasting unresponsiveness
has been observed in some individuals. One recent study
demonstrated that the immune response to the leprosy bacillus
elicited in UV-irradiatcd skin of healthy, immune subjects was
significantly reduced, compared to that in unirradiated skin of the
same individuals (4). This study is one of the few to date in human
subjects that investigates the effect of UV radiation on the immune
response to an infectious organism.
Taken together, information from the animal models and the
limited data available in humans give reason to believe that
increased UV-B radiation could increase the severity of some
infections in human populations. Furihcrmorc, skin pigmentation
154
docs not seem to provide much protection against the
immunosuppressive effects of UV irradiation in humans, suggesting
that the population at risk of such effects is very large. Because
infectious diseases constitute an enormous public health problem
woridv^ide, any factor that reduces immune defenses and increases
the severity of infectious diseases is likely to have a devastating
impact on human health. At the present time, however, not a single
prediction about the impact of ozone depletion on a single infectious
disease in a single geographic location can be made. Unless
additional information is obtained, this situation will not change.
REFERENCES
1. UNEP report on Environmental Effects of Ozone Depiction 1994.
Ambio 24:138-196, 1995.
2. Pollock PM, Yu F, Qiu L, Parsons PG, Hay ward NK. Evidence for
U.V. induction of CDKN2 mutations in melanoma cell lines. Oncogene
11:663-668, 1995.
3. Drobetsky EA, Turcotie J, Chateauncuf A. A role for ultraviolet A
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155
Mr. ROHRABACHER. Thank you very much, Doctor. I would note
that your testimony does have a lot of "may"s and "could"s in it,
and that you actually are highlighting that, to the sense that you're
saying that further study must take place and that not enough
study has been done to make the conclusions of what may or could
happen.
I think that's really an important consideration when looking at
this issue.
Before we go on to questions, and I'll go directly to the Members
of the Committee, but let me just say one thing for the record from
the Chairman's point of view.
And that is that quite often in history, we see cases where all
of the experts are on one side and within a few years, all the ex-
perts are on the other side.
So, I am not swayed by arguments that here's a big list of sci-
entists that are on my side and you only have a smaller group of
scientists on your side.
I'm just not swayed by that at all.
I note that five years ago, the idea of a single-staged orbit rocket
system for the United States was derided. Today, everybody in the
industry looks at that. That is our great hope, for a single-staged
orbit.
But five years ago, it was being laughed off as just something
that eccentrics argued in favor of. And this can be shown time and
time again.
I understand that, for example, in the case of when someone has
certain diseases, for example, and — I'm thinking about heartburn.
What's the disease I'm talking about here?
Ulcers. Where the medical profession has a totally different view
of ulcers today than it had five years ago, and that the vast major-
ity of doctors swore that it had something to do with acid and ten-
sion and now they claim it's bacteria. And in fact, they used to say,
drink a glass of milk. And now they say that's the very worst thing
you can possibly do.
So when we're looking at things like the ozone hole, or we're
looking at things that deal with scientific judgments, let us be hon-
est enough to look at the arguments, rather than trying to belittle
the other person's position by saying that these are erratic argu-
ments, rather than going to the heart of the argument.
That's what we have a panel of people before us today for, who
have different points of view. And what we're interested in is which
one of those views is correct, not who has more people on their
side.
With that
Mr. BOEHLERT. Mr. Chairman, may I just make an observation
there?
Mr. ROHRABACHER. Certainly.
Mr. BoEHLERT. First of all, I want to compliment you on the com-
position of the panel because, obviously, we have diverse points of
view represented on the same panel.
And I know you and I have discussed this many times, the frus-
tration we had when we were in the minority, that the alternative
side was called at 4:00 in the afternoon, after everybody had de-
parted.
156
This is refreshing to see this balance on this panel.
But I would make this other observation. I think we have to go
with the best available science at the time. We're never going to
have absolute certainty.
And the example you use, the single-staged orbit rocket, that was
an engineering problem, a little bit different than hard science, as
we're discussing it.
But I want to compliment you very much for the composition of
this panel and the manner in which you're conducting the hearing.
Mr. ROHRABACHER. Okay. Thank you very much. And Mr. Ehlers
will be the first Member of the Committee to have questions. And
we will, as I say, hopefully, try to have questions that are aimed
at promoting dialogue among the panelists.
Thank you.
Mr. Ehlers. Thank you, Mr. Chairman. The very first is a spe-
cific question to the last member of the panel. This issue of immu-
nology relating to this, or immune response, is new to me.
It wasn't quite clear to me from your testimony how this works.
Are you talking only about those infections or diseases which enter
through the skin, and that irradiated skin has a reduced immune
response? Or is it a more general, systemic problem?
Dr. Kripke. In the animal models at least, there are two ways
in which ultra-violet light can change the body's immune system.
One is exactly as you've stated, where an organism, a foreign sub-
stance, comes through UV-irradiated skin and then the immune re-
sponse to that organism is decreased.
But it is also true in the animal models that ultra-violet irradia-
tion causes systemic immune suppression, so that some organisms
can be introduced at non-irradiated sites and still have an in-
creased disease-causing pathway.
Mr. Ehlers. Okay. As a fair-skinned individual, this makes plain
why I get sick all the time. [Laughter.]
I would like to go back to my opening statement and relate to
that and then ask all of you to respond to a specific question.
I made my comments at the beginning about the uncertainty of
a good deal of scientific evidence when it's difficult to do the experi-
ments, which it is in this case, certainly.
It seems to me the disagreement we have on the panel reflects
this difficulty. But it seems to me it's at different stages.
If you look at the issue of the presence of CFCs or their kin in
the atmosphere, that can be determined with a fair degree of cer-
tainty. We now have satellite measurements of that and other ap-
proaches. It's working quite well.
So we have a good deal of certainty there.
The impact of the presence of CFCs on ozone, the total amount
of ozone there is less well understood, I believe, and certainly not
as accurately measured. Partly, I believe, because the mechanism
may not be totally understood, largely because of the natural fluc-
tuations in ozone.
So it seems to me that there, you're introducing a fair amount
of uncertainty.
But the real issue that we get concerned about and the basis
upon which we form public policy is the health effects of the ozone
depletion.
157
I appreciated Dr. Setlow's comment about the funding is in-
versely related to the uncertainty, and I think that's a very valid
point.
But I would be interested in the response of each of you to the
following question — what should we do as a Federal Government to
try to reduce the uncertainty involved here? Where are the most
fruitful areas of research in determining what we really have to
know in terms of public policy?
And that is, what is the correlation between CFC use and health
effects?
That's, I think, the crux of what we're examining here as a panel
today. And which areas of science need the most research? Where
are the greatest uncertainties in that? Is it perhaps the fact that
there are other ozone-depleting chemicals around that we haven't
observed as carefully and don't know the effects on?
What can we do in terms of control of the natural chemicals up
there? Can we have anything to do with that, such as methane and
others?
Just a whole host of questions here and the time is limited, so
I'd like to have you each try to zero in on what you as an individ-
ual panel member think we should be doing in terms of trying to
pin down this uncertainty, get the kind of results that will convince
not only me, but Chairman Rohrabacher and others of the proper
avenue to take in public policy.
Dr. Watson.
Dr. Watson. Thank you. I start with a premise which is slightly
different.
I believe we do know enough to firmly establish the relationship
between human activities and loss of ozone. I don't think there's
any question whatsoever based on incredible amounts of laboratory
data, of both homogenous — that's gas-phase — and heterogenous
chemistry or observations of aircraft, balloon and satellites.
There is no doubt in my mind and the large majority of scientists
that we have established cause and effect over Antarctica. None
whatsoever. And that when you have ozone depletion over Antarc-
tica, you get more UV-B.
The two big areas where I do believe we do not have what some
people would like to see as sufficient evidence is well-determined
trends of ultra-violet radiation at the earth's surface, at mid-lati-
tudes, where we all live. And also whether or not there is a direct
relationship, or what that relationship is, between ultra-violet B
radiation and melanoma.
So I believe we have established beyond doubt the ozone is de-
pleting because of human activities. Unfortunately, we do not have
the right ground-based system at mid- latitudes to observe that
predicted increase in ozone. But we also do know that some of the
health effects are well established, that is, UV-B and
nonmelanoma. And as Dr. Kripke said, even in those cases, half to
one percent of the cases are fatal.
So we have got a link. The two weaknesses, therefore, ground-
based observed at mid-latitudes of UV-B, and a better understand-
ing of some of the non-melanoma health effects, the other things
other than non-melanoma.
Mr. Ehlers. Thank you.
158
Dr. Singer. I'd like to comment on your question. Your question
relates to the health effects.
I'm not a health scientist and therefore, I have to use what I
would call a common-sense approach to this problem.
We've heard from Dr. Kripke about what she regards as the dev-
astating health effects of a small increase in UV-B. By small in-
crease, I suppose she means five or ten percent, the type of in-
crease that's being envisioned as a result of the putative ozone de-
pletion.
I just want to point out that if you move from New England to
Florida, you get an over 200 percent increase in UV-B because of
the steeper sun angle. It has nothing to do with ozone, really. It's
the steeper sun angle, same amount of ozone.
And therefore, if the effects were really devastating, looking at
it now as a physicist, not as a health scientist, I would expect to
see all kinds of epidemics in Florida, people whose immune sys-
tems were collapsing.
I would see epidemics of cataracts and all sorts of things because
of the much, much higher levels of UV-B in Florida, which exist
naturally.
Mr. ROHRABACHER. Well, Dr. Singer. Let's ask the two, then.
Are there such epidemics taking place in Florida of cataracts and
melanomas?
Dr. Kjiipke. I can't answer the question about cataracts. That's
not my area of expertise. Perhaps someone else can.
Mr. ROHRABACHER. Is there any information on cataracts because
cataracts was something that was brought up earlier. It was in
your testimony, I believe, that it would have an impact on cata-
racts.
Do we have any evidence for it?
Dr. Singer. Well, I've read a paper by Professor Schlein. Oliver
Schlein is a professor of ophthalmology at Johns Hopkins Univer-
sity. He published a paper this year, in April of 1995. The work
was supported by EPA and NASA.
He went down to the Antarctic to study the effects on eyes of in-
creased UV-B. He reported no effect.
Mr. ROHRABACHER. What about between the northern part of the
United States and the southern part of the United States?
Dr. Kripke. I think that the part of the world that is more likely
to be affected are parts of the world where sunglasses are not
available and cataract surgery is not available.
There are ways to decrease the impact of ultra-violet radiation
on the eyes, such as wearing sunglasses. We can prevent blindness
from cataracts by cataract surgery.
So I think the place that you would expect to see the biggest im-
pact of those kinds of effects of ultra-violet light are in underdevel-
oped countries where those mitigating factors are not available.
Mr. ROHRABACHER. Do we have any evidence of that happening?
Dr. Kripke. I can't answer that question.
Ms. Rivers. The nonmelanoma cancer.
Mr. ROHRABACHER. Nonmelanoma cancer.
Ms. Rivers. Is it not true that there are higher incidences in cli-
mates closer to the equator?
159
Dr. Kripke. That is clearly true. There is a latitude gradient for
skin cancers.
I don't think there's any question that nonmelanoma skin cancer
is related to ultra-violet B radiation. I can't imagine that there is
still anyone in the world who doesn't believe that UV-B radiation
is not the major cause of nonmelanoma skin cancer.
So one thing we can say for absolute certainty is that if UV-B
radiation at the earth's surface increases, there will be more cases
of nonmelanoma skin cancer.
I don't think anyone will argue with that.
Dr. Singer. Just to complete my answer to you, I agree that in-
creased UV-B will produce more nonmelanoma skin cancers.
The question really is how many more?
Mr. ROHRABACHER. Dr. Setlow, you're the other health specialist
with us on the panel today.
Dr. Setlow. You have to understand that my background origi-
nally was in physics, and that makes me an expert in health.
[Laughter.]
Mr. ROHRABACHER. Thank you.
Dr. Setlow. The important point about diseases is that they
have to be enumerated. And in the case of certain cancers, there's
a good registry. They're reported. Melanoma is reported.
Nonmelanoma is not reported really in any rational way, and cata-
racts certainly are not reported to a central registry.
So it's very difficult to get those data over the U.S. It's very easy
to get melanoma data and, with special surveys, nonmelanoma.
And it's very clear, as Margaret Kripke said, there's a lot more
nonmelanoma in sunny climates. The best and biggest comparison
comes between Australia and Norway, similar kinds of fair-skinned
populations.
Nonmelanoma in Australia is about 20-fold greater than in Nor-
way, a tremendous difference. Melanoma in Australia is only about
two-fold greater than in Norway.
So there's either a very different dose response relation or a very
different wavelength relation, which you can't tell from the epide-
miology.
Mr. ROHRABACHER. I think the central question is whether or not
this relates to the depletion of the ozone and how does that fit in
with this?
Dr. Albritton.
Dr. Albritton. Thank you, Mr. Chairman.
I am an atmospheric chemist and by no means an expert in
health. The only area of health that I am an expert in is that of
airline food on human beings. [Laughter.]
But I do know who to check with on advice. I pointed out earlier
that there is an assessment panel on effects and Dr. Kripke partici-
pated in that and described it on hers. And I did recall, and as I'm
asked questions on areas that I don't know anything about, having
looked up issues in the health effects assessment.
You had asked about cataracts. Let me just read to you the oph-
thalmologist's reports in the health effects assessment.
It's noted that a 1 percent increase in stratospheric ozone deple-
tion has been predicted to be associated with a 0.6 to 0.8 percent
160
increase in cataracts. This estimate, although crude, has not been
improved upon since the last assessment.
So that's their current statement on the role of ozone depletion
and cataracts.
Thank you.
Mr. Ehlers. Dr. Baliunas next?
Dr. Baliunas. The question was where to put areas of research
funding.
I would guess accurate UV-B ground-level measurements are
really needed because the current measurements are fraught with
uncertainty.
There also should be, and I believe there is, research on the envi-
ronmental and health impacts of the replacement chemicals that
are being phased out.
So we thoroughly understand their impact on the environment as
well, whether or not the replacements are causing, will cause acid
rain problems.
Mr. Ehlers. Thank you. Dr. Setlow.
Dr. Setlow. I come back more or less to my original statement.
And that is we're concerned, not because of the ultra-violet, but be-
cause of the effects on life on Earth. And therefore, there has to
be more money put into the area of greatest uncertainty.
What are the effects on biological systems?
I'm sorry to say that, in most cases, you're only going to get this
by putting more money into that field. And I'm not sure exactly
how to do it. I can give you my prejudices, but they're only preju-
dices.
I happen to be prejudiced in favor of fundamental research. Tell
people you have to know something about these effects. And if
there's money, lo and behold, the answer, might/may appear.
Without that, the answer will not appear.
Mr. Ehlers. Dr. Kripke.
Dr. Kripke. I also — I guess we all have our own biases based on
our background and interest in this area.
But I think the most important thing from my perspective is un-
derstanding what are the consequences of UV-B radiation. And
again, we have very little information on some of those potentially
important effects.
I think the two most important ones, really, are the
immunological, potential immunological effects of UV-B radiation
because the order of magnitude of that problem may be large. Lots
of people are susceptible. It doesn't take much ultra-violet light to
alter the immune system.
The other area of uncertainty I think it's very important to have
information on is melanoma. I think we are currently in a stage
of scientific development where a little bit of money put into that
question for human melanomas will probably go a long way.
I think we can get some useful answers by doing some critical
experiments in humans of that kind.
I agree with Dr. Baliunas that I am concerned about replacement
CFC compounds, and I think that we do need to know what are
the potential health consequences of those compounds as well.
So those would be my three areas where I think we need more
information and/or more research.
161
Mr. Ehlers. Thank you. And Mr. Chairman, it appears that the
consensus is that we need better data on UV reaching the earth,
both UV-A and UV-B, but especially UV-B.
Secondly, identify the effects of that on human health.
And thirdly, take a look at some of the replacement chemicals.
Thank you very much.
Mr. ROHRABACHER. Mr. Ehlers, thank you very much.
Now Mr. Olver.
Mr. Olver. Thank you, Mr. Chairman.
I'm glad somebody summarized the last five or six statements be-
cause I'm not sure that I would have been able to have picked out
exactly what that summary was from the comments made.
Let me just ask a quick question of Dr. Singer and Dr. Baliunas.
Do you think there should be any controls on the CFCs that are
being produced at the present time, given the data that we have?
Dr. Singer. This is really not a scientific question, I take it. You
want my personal feelings on it?
Mr. Olver. Yes.
Dr. Singer. I really have no strong personal feelings about CFCs.
My real concern in this whole matter, the reason I'm in this, I don't
have a vested interest in this matter at all. It's just to make sure
that the science that backs our policies is properly conceived, the
science is properly done.
Mr. Olver. Well, does the science, as it is now, suggest that we
should or should not be controlling CFCs?
Dr. Singer. I'm more concerned about the fact that I see the
science being misused, mishandled, distorted. That's been my
theme.
Mr. Olver. Okay.
Dr. Singer. And I'd like to make sure that all sides of the sci-
entific issue are aired and properly discussed.
Mr. Olver. Would you like to answer that, comment on it?
Dr. Baliunas. Well, I also have no preference. Some of the nar-
row question addressed here of the accelerated phase-out or delay
over the next four years, as the advancement of the phase-out from
the year 2000 to 1997.
Mr. Olver. You're against the phase-out, the advancement of the
phase-out?
Dr. Baliunas. Not personally. It's just that it involves a broader
issue than the science. It involves the risk/benejfits. And I can't
comment on those, and the second panel shall.
It involves an economic question as well.
Dr. Singer. Can I come back to your question? Perhaps I can
shed some more light on this.
Specifically, I am in favor of delaying the phase-out to the origi-
nal date of 2000. I'm not against the phase-out of CFCs, as such.
But I think that we're proceeding in a very hasty way, on the
basis, for example, of a theory which has never been proven.
Let me just remind you of the fact that this theory that underlies
all of this, the so-called CFC ozone theory, was not able to predict
the Antarctic ozone hole, the biggest thing we have, a genuine
event, genuine phenomenon.
Never predicted by the theory. It came as a complete surprise.
162
Well, this theory has been changing every year. Every year. You
look at the National Academy of Sciences and study their reports.
Every two years, they've come up with a prediction of ozone deple-
tion which was different by a large amount.
Therefore, I think it pays for us to kind of take stock and do a
good job on the theory, on the observations, on the UV-B measure-
ments, before we take hasty and, I think, economically very de-
structive actions.
Mr. Olver. I guess I'm fearful that if one waited until the cer-
tainty of the chemistry and the immunology in a process like this,
that we may have been left with something which is either irre-
versible or exceedingly difficult to reverse, the timeframes on that.
I recognize and I'm sensitive to what the Chairman had said ear-
lier about theories. It was only earlier in this century that the first
people who suggested plate tectonics were essentially driven from
their field in disgrace. But now everybody in those fields certainly
believes it.
I was kind of curious. Let me — it's terrible. I would like to follow
a number of different points of questioning here. But I'm sort of cu-
rious from Doctors Watson and Albritton.
If you took the spectrum of scientists over a range of from zero
concern about this issue to — zero to 100 scale, where the 100 is in-
tense alarm over the issue — where are the number of scientists?
Where is the scientists?
You have your data with large numbers of scientists who sign on
to what is an average kind of position. But where is that averaged
positioned?
Some of them do not view the same alarm as some others within
those who have signed on to the data. And where are those who
have not signed on? How many of them — what's the distribution of
atmospheric scientists or people who work over this whole issue, if
I may ask?
Would anyone be able to give me what the distribution looks like,
where they are on that scale?
Dr. Watson. Obviously, I'm biased. I've been associated with
international ozone assessment since 1981 and I've either chaired
or cochaired with Dr. Albritton all of the assessments involving
hundreds of scientists from around the world, and they do come
from all walks of life.
As I said in my testimony
Mr. Olver. Where is the center of the distribution?
Dr. Watson. I believe that 95 to 100 percent of the scientists —
I can't say 100, because, obviously, there's two at this table who do
not believe it — 95 to at least 99 percent of the scientists believe
those documents on the table in full.
Mr. Olver. All right. I'm not going to get an answer in the terms
that I was looking for it, in any case there. But that's okay. I can
understand why that might be.
Let me follow a question here between the two biologists, one
physicist, actually, who's admitted to being a physicist rather than
a biologist, on this question.
In the data, Dr. Setlow, in your data, you have mentioned that
in fish melanoma, 90 percent is UV-A, 90 percent comes from
163
UVA. And in mouse melanoma, nonmelanoma, 95 percent is UV-
B.
In fish, is nonmelanoma also very heavily UV-B? Is this some-
thing that I should be able to take away, that nonmelanoma is
heavily UV-B?
I'm not sure that one can have melanoma in mice.
Dr. Setlow. One can have melanoma in mice.
Mr. Olver. And is that heavily UV-A? Do I see that across all
of the animal kingdom?
Dr. Setlow. The experiments on mice have not been completed
for melanoma.
Mr. Olver. Some of you physicists, give me a relatively narrow
range of what UV-A and UV-B is.
Dr. Setlow. Okay. UV-B, depending on to whom you speak, is,
roughly speaking, 290 to 320 nanometers.
Mr. Olver. Yes.
Dr. Setlow. And that is what is absorbed by ozone, primarily.
Mr. Olver. That's B.
Dr. Setlow. That's B. UV-A goes from 320 to 400. That's the
visible.
Mr. Olver. Okay. Now, if we're talking about that, you have in-
dicated that the rate-limiting step in the biological process on mela-
noma is not known. I think I've got that correct, that you think the
rate-limiting step is not known.
It seems to me that, while we may be looking at broad spectra
here, that what is likely to be happening, likely to be happening —
I'm perhaps way out on a limb on this — but where there would be
specific site processes within the DNA molecules or non-DNA mol-
ecules since only a portion — is all of this affected?
You spoke of DNA molecules. Is all the melanoma believed to
come from reactions in the DNA molecules?
Dr. Setlow. The simple answer is yes. The more complicated an-
swer is that DNA absorbs strongly in the UV-B region. And every-
one believes that UV-B definitely affects DNA directly.
Mr. Olver. Is the belief that this is really kind of a general,
across the spectrum of UV-B, or is in site-specific locations
where
Dr. Setlow. No, no.
Mr. Olver [continuing]. On the DNA molecule?
Dr. Setlow. All the UV-B, from, roughly speaking
Mr. Olver. That take in specific energy.
Dr. Setlow. In specific places in the DNA.
Mr. Olver. Specific places, this is going to be rather specific en-
ergy.
Mr. ROHRABACHER. Mr. Olver, I'll let you finish this line of ques-
tioning, but we should move on.
So if you could wrap it up.
Dr. Setlow. I don't think this is the question to get into an
elaborate discussion of absorption.
Mr. Olver. Well, that may well be. I think what I was surprised
at was your comment after — and I'll finish with this — that while
we don't know what the rate-limiting step is, which is specific
chemical reaction steps, that's the very implication of the rate-lim-
iting step that goes on in this process, that then you followed that
164
by saying that you — I think I've got this correct — that you believe
that melanoma is not ozone-related, but life-style-related.
You, as a physicist and a biologist working in this field, have
moved from what research gets very specific, to an extremely gen-
eralized kind of a comment.
Mr. RoHRABACHER. As a surfer, as the only surfer in the room,
I'm going to say this is the last question.
So go right ahead.
Mr. Olver. Fine.
Dr. Setlow. Okay. I said, if you assume that humans are like
fish, that conclusion held. The complication is that melanoma
arises in pigment cells, melanocytes. And melanin absorbs at all
wavelengths and it is possible that energy, light energy absorbed
in melanin, may ultimately affect DNA by indirect mechanisms.
Mr. Olver. And the melanin itself is part of that DNA molecule.
Dr. Setlow. No, it is not. It's another thing. Let's call it a sen-
sitizer, if you like.
There are a whole bunch of pigments.
Mr. Olver. What does it mean, then, that you tell that it comes
from DNA, from alterations of the DNA.
Dr. Setlow. Oh, yes.
Mr. Olver. But the melanin, which is specifically absorbing the
UV-B, is not part of the DNA molecule.
Dr. Setlow. The melanin is sitting on the side. The melanin ab-
sorbs energy and goes — whap, to the DNA.
Mr. Olver. Oh, I see.
Dr. Setlow. That's the way it would happen.
But what I meant by rate-limiting steps is the initiation, the
start of an altered cell comes from a change in the DNA, whether
directly by light energy absorbed in the DNA or absorbed melanin,
perhaps.
Mr. Olver. So the melanin, in this instance, is acting somewhat
like a free radical.
Dr. Setlow. Correct.
Mr. Olver. Once it has absorbed the energy and then that is the
thing in its free-radical state that attacks the DNA molecule and
it is the alteration of the DNA molecule that produces the mela-
noma.
Dr. Setlow. That's a possibility, yes. That's an explanation.
Mr. Olver. And the melanin is back in a position to
Dr. Setlow. What I was thinking
Mr. ROHRABACHER. Thank you.
Dr. Setlow [continuing]. On the rate-limiting step.
Mr. ROHRABACHER. Thank you, Mr. Olver. And maybe you'd like
to finish.
Dr. Setlow. You start with an aberrant cell that can give rise
to a melanoma. But there may be immuno-suppressive effects that
prevent that cell from growing and becoming malignant. And so,
the immune system may be important also in melanoma develop-
ment. If you have a good immune system, you may have less mela-
noma.
We don't know which is the most important.
Mr. ROHRABACHER. Thank you very much, Doctor.
165
Mr. Olver. Mr. Chairman, no question. But I still am quite sur-
prised that after this discussion, and even as we've just gone
through this, that Dr. Setlow is so specific about how one does this
and then says that it's life-style, as opposed to not knowing what
the rate-limiting steps are.
Mr. ROHRABACHER. The good doctor may well mean that we surf-
ers who spend our time out in the sun voluntarily for a large num-
ber of hours have more of a chance of getting melanoma than a
nun who's totally covered by her cloak.
Those are choices that people make.
Mr. BOEHLERT. Are you saying that nuns don't surf? [Laughter.]
Mr. ROHRABACHER. Well, we'll get back to that one later.
Now we'll have Ms. Rivers, who may want to ask Mr. Singer
about his peer review, the number of peer-reviewed articles that
he's written.
Ms. Rivers. Before I do that, I would like to ask Dr. Watson, Dr.
Albritton, Dr. Setlow, and Dr. Kripke, if they are familiar with a
publication called the Journal of the Franklin Institute, with what
regard that journal is held in the scientific community, and if they
know whether or not it is maintained in the library of the institu-
tion at which they work?
Dr. Watson. This is a journal ^ that came to my attention this
morning for the first time. It is not in the library of the White
House. It began in 1994, with a circulation of 400 people.
It is obviously in a number of libraries and businesses and a
number of institutions. We understand its circulation is 400.
Ms. Rivers. Okay. Dr. Albritton, are you familiar with it, or is
it in your institution?
Dr. Albritton. That journal is not in our institution. I'm not
aware of it, nor have I heard it discussed at ozone-related scientific
meetings.
Ms. Rivers. Okay. Dr. Setlow.
Dr. Setlow. I'm familiar with it from my early, early days as a
physicist, but I have not seen it for many years and, to the best
of my knowledge, it is not in our institution at the present time.
Ms. Rivers. Dr. Kripke.
Dr. Kripke. I've never heard of it.
Ms. Rivers. Okay. Thank you. Dr. Singer, I have a list of docu-
ments that, having talked to a lot of people, seem to have general
agreement that these are the fora in which this issue is discussed
on a regular basis.
I'd be curious to know if you believe there are others that should
be on this list, and we'll see if others agree — Science, Nature, Geo-
physic Research Letter, the Journal of Geophysical Research, At-
mosphere and Environment, Physics Today, the Journal of Physical
Chemistry, and the Journal of Chemical Physics.
Are you aware of others that you think have that sort of broad
readership and broad contribution that should also be on this list,
such as — in the area of ozone depletion, the discussion of ozone de-
pletion.
Dr. Singer. Well, I would probably list another half-dozen jour-
nals.
'See letter from Dr. Watson to the Chairman pertaining to this section of the dialogue.
166
Ms. Rivers. Such as?
Dr. Singer. EOS, which is the house journal of the American
Geophysical Union.
Ms. Rivers. Okay. I'll let you stop with that.
I went back through because I wanted to be careful about what
I said. I went back through our information. And from at least
1980, in the document list that I gave you here, which are the
main journals of discussion in ozone depletion, we found only one
article by you — and that was not an article. That was a comment,
a technical comment, over the last 15 years.
Am I incorrect? Have you actually published in peer-reviewed
documents of these calibers in the last 15 years, articles on ozone
depletion, original research on ozone depletion?
Dr. Singer. Well, you have a list attached to my testimony and
you're very free to peruse any of the references therein.
Ms. Rivers. Well, I'm asking you, the question that I'm asking
you.
Dr. Singer. Including references in Science and Nature, which
are listed there, and EOS.
Ms. Rivers. I have Science, a technical comment in Science.
Dr. Singer. How many would you be satisfied with?
Ms. Rivers. Well, EOS which you just gave me, I understand is
a newsletter and not a peer-reviewed document.
Dr. Singer. That's not true.
Ms. Rivers. Okay.
Dr. Singer. Not true.
Ms. Rivers. We have a difference of opinion. But my statement
earlier, which came around the comments about published re-
search
Dr. Singer. And actually. Technology is also peer-reviewed. The
Journal of the Franklin Institute is peer- reviewed, and I wish the
editor were here to reassure you.
Ms. Rivers. But it has not the caliber or the distribution of the
list that I read a few moments ago.
Dr. Singer. I have no idea what the distribution is.
Ms. Rivers. Okay.
Dr. Singer. I was asked by the editor to write an article, which
I did.
Ms. Rivers. But my question is, in these documents, these well-
recognized scientific, peer-reviewed documents, have you published
anything other than the technical comment, which is a response to
someone else's article, on ozone depletion in the last 15 years?
Dr. Singer. Ozone depletion hasn't been around as a subject for
that long.
Ms. Rivers. Or for however long they've been around. Well, then
you said earlier you published 200 articles.
Dr. Singer. How far back do you want to go?
Ms. Rivers. Well, if ozone depletion hasn't been around for many
years, or for that many years, but you claim that you've published
before on ozone depletion, I'm finding stuff only from the early '70s
by you on ozone depletion and earlier.
Dr. Singer. 1971, there's a fundamental paper on ozone deple-
tion.
Ms. Rivers. Okay. So it existed at least then, ozone depletion.
167
Dr. Singer. You can start there if you like, certainly.
Ms. Rivers. All right. I'm curious to know, and I have to say, the
reason I didn't ask
Dr. Singer. I don't see the relevance to your question, but please
go ahead.
Ms. Rivers. Dr. Baliunas, the question about whether you had
the document, I notice that both of your institutes, the George Mar-
shall Institute and the Science and Environmental Policy Project,
have the same chairman of the board of directors and have three
board of science advisors in common, which is pretty interesting.
What other collaboration do the two organizations have?
Dr. Singer. Let me answer that question, if I can.
I don't think that we have any formal collaboration that I can
point to.
Am I wrong on this?
Dr. Baliunas. No collaboration underway and none that we've
ever done.
Ms. Rivers. Okay. Just a coincidence that the same people are
on the board.
Dr. Baliunas. Just a coincidence.
Mr. Rohrabacher. Ms. Rivers, your time is just about up.
Ms. Rivers. Thank you.
Mr. Rohrabacher. If you have one last question to ask.
Ms. Rivers. I do. Given that the overwhelming number of sci-
entists who are working on this topic fall on the other side of both
Dr. Baliunas and Dr. Singer, I wonder what your explanation for
that is.
Is there some sort of conspiracy to keep them
Dr. Singer. Yes, I have an explanation.
Ms. Rivers. Okay. Great.
Dr. Singer. Would you like to hear it?
Ms. Rivers. Yes, I would.
Dr. Singer. In the case of the ozone depletion work, my work has
been ignored. My papers have been ignored and you will not find
a reference to an3rthing that I've published in here, no matter when
it was published.
In the case of global warming, we have actual evidence which I
can cite to you, because in the case of global warming, we have a
published book called Global Climate Change. And in the book, the
editors of the book, who happen lo include Dr. Watson, say that
there was a minority of scientists who did not agree with the con-
clusions.
They failed to state whether the minority was one percent or 49
percent, so we don't know. But they do say that they couldn't ac-
commodate the views of the minority. And they didn't.
Ms. Rivers. Okay. Dr. Albritton, would you like to respond to
that, given that you've worked on these issues?
Dr. Albritton. Yes. I am confused by Dr. Singer's statement
that his paper was ignored. His one paper that has been referred
to, the comment, is referenced on page 9.21 of the current assess-
ment.
It also references the reply of the original authors about whom
he was commenting.
168
And so we not only had included the original paper. We included
comments and discussion related to both sets of comments on that
paper.
Ms. Rivers. Thank you. Thank you, Mr. Chair.
Mr. ROHRABACHER. Just a note before we go on to Mr. Boehlert,
that there have been times in history, and I think the panel will
agree, and probably everyone in this room will agree, when the
large majority of scientists changed their views on something that
they were very adamant about.
Just to follow up on your question, has there been any situation
where — and quite often, when the vast majority of scientists be-
lieved in something, they actually were somewhat aggressive and
somewhat repressive towards other people who brought up another
point of view.
Has anyone on this panel experienced that? In other words,
maybe some scientists are keeping their head low because the fact
is that the common knowledge of the day happens to be that ozone
is a major problem and anybody questioning that might feel some
pressure.
Does anyone want to comment on that possibility?
Dr. Singer. My comment on that is that my impression is that
a large majority of scientists do support the present ozone story.
Mr. ROHRABACHER. Yes.
Dr. Singer. Dr. Watson, at the last hearing last month, referred
to me as a minority of one. I think he mJght want to change his
mind after today. At least we have two or maybe more here.
The problem is that there are many, many scientists who do not
speak up. And the reason they do not speak up is because they do
not want to lose their research funding.
I have personal experience with this and I think Dr. Baliunas
can probably enlighten you on this matter further.
Mr. ROHRABACHER. Dr. Baliunas — well, Dr. Watson first, and
then Dr. Baliunas.
Dr. Watson. Thank you, Mr. Chairman.
You're absolutely correct. The majority of scientists have in some
cases been proven wrong, as history tells us.
I think after the international ozone trends panel came out in
1988, where we first noted the ozone trends, not only in Antarctica,
but in high northern latitudes, there was a real question of wheth-
er they were correct or not.
Allied Chemical vehemently believed they were wrong. So did
DuPont and so did many of the chemical industry.
A country, the Soviet Union, at that time also believed they were
completely wrong.
Allied Chemical put some of their very best statisticians on the
job to try and disprove the ozone assessment. The Soviet Union
also put some of their best statisticians.
That's what I mean when, many times, minority views, the ma-
jority views have been challenged by the minority. They now are
key players in the international assessment.
So I believe that not all funding comes from the U.S. Govern-
ment. It comes from some very conservative governments around
the world, and it also comes from industry.
169
Mr. ROHRABACHER. And Dr. Watson, now that it is the commonly
accepted position that the ozone hole is a major threat, do you be-
lieve that some people might be a little, let's say, heavy-handed in
their dealings with people who disagree with them on this issue?
Dr. Watson. Obviously, as you say, I speak aggressively and I
would not deny that.
However, I do believe that through the international peer-review
process, and journals, I believe the minority of scientists have
many, many avenues through which they can get their minority
views to the public.
Mr. ROHRABACHER. Dr. Baliunas, would you like to comment?
Dr. Baliunas. Most chilling is that I've been directly told by offi-
cers of federal funding agencies not to apply for funding to work
on, quote, certain questions, in this area.
They give two reasons.
One is that answering these questions would undermine the pos-
sibility of getting new funds. And this suggests a complete break-
down of the peer-review process.
In addition, answering these questions, or even investigating
them, might deter policymakers from, quote, doing the right thing.
Mr. ROHRABACHER. I think that that is — this is what happened
to you?
Dr. Baliunas. This is what happened to me, personally. There
are many other stories, but they are hearsay, and so, I don't want
to repeat them.
Ms. Rivers. Mr. Chair, we should get names and dates and
places and investigate this, because if there are agents, scientific
agencies in this country who are giving that kind of information,
we should know it.
So I would ask that Ms. Baliunas give times and names.
Dr. Baliunas. I would be glad to submit that. In fact, I've been
badgered. My staff has been badgered in the last several days, my
superiors, by an advocacy group, once the witness list came out.
The employer that employs me is unrelated to this testimony.
Nevertheless, they've been calling and calling and calling and badg-
ering them, and this has had great effect. It's disrupted my work
environment. It's an attempt to intimidate me and to censor
my
Ms. Rivers. This was a federal employee that was doing this?
Dr. Baliunas. No. This is an advocacy group, going to one of my
employers completely unrelated.
Ms. Rivers. You started out when you said applying for grants
for the Federal Government.
Dr. Baliunas. Those were federal employees.
Ms. Rivers. And you can give us names and times?
Dr. Baliunas. Yes. And what I did early this morning, but did
not send, was, due to these institutional pressures, I almost with-
drew from this hearing. I just did not fax this to you at the last
moment.
Mr. ROHRABACHER. I do think that that is a rather significant
element that's been introduced into the testimony today. And it
also reflects that some people who are naturally not inclined to
buck the common knowledge, that perhaps there's been even some-
thing that's been added to that in the sense that, today, when we
170
have so many people involved in science that actually receive their
funds from federal grants, that this is a very serious charge.
We'll go back to that.
Mr. Boehlert, we have time for five minutes' worth of questioning
from you, and then we will break for the vote.
Mr. Boehlert. Mr. Chairman, I'd like to observe, we've had a
depletion problem of our own.
When Dr. Ehlers, who has a Ph.D in physics, left, the scientific
expertise of this group up here declined by 100 percent. [Laughter.]
We have difficulty because we're generalists at best, for the most
part. So we have to look to the experts for advice to guide our pol-
icymaking.
And when the preponderance of scientific testimony supports one
direction, that usually is a direction I am comfortable with.
So, Dr. Albritton, I'd like to ask — I'm sure there was some dis-
pute in all the studies you cite there. But how broad and how deep
was the consensus?
Dr. Albritton. A few points on that, sir.
First of all, the summary of the document was prepared by the
peer review panel and authors, all simultaneously. And that is, the
wording and the consensus statements in here were agreed upon
by over 80 international scientists that included not only the au-
thors of the chapters, but those who had written, peer-reviewed
them, and also participated in a verbal peer review.
I would indicate, in terms of this booklet and the words in there,
that the agreement of that group that prepared the larger book was
100 percent.
Mr. Boehlert. Let me be very specific. Dr. Singer made a num-
ber of assertions disputing whether UV-B is increasing.
What do you believe is wrong with his assertions?
Dr. Albritton. Would you repeat that, sir?
Mr. Boehlert. Well, Dr. Singer made a number of assertions
disputing whether UV-B is increasing. He made those assertions.
And I'd like to know what you think is wrong.
Dr. Albritton. Yes. I'd reply to that in two ways.
What is absolutely sure, numerous data sets indicate and dem-
onstrate with direct measurements of overhead ozone and surface
UV, that when overhead ozone decreases, that surface UV in-
creases.
That's been shown, as indicated earlier, in several studies, direct
measurements.
What we lack because of the shortness of the measuring record
is any long-term trend in the change of UV. Several reasons for
that.
It's a difficult measurement. Some of the earlier studies were
placed in areas where pollution could interfere with that, and that
the modern instruments started only a few years ago.
So I fully support the research statements made earlier that we
need to foster and support that start that we've made.
But the fact that we have not yet observed over that time scale
a trend, does not imply that a loss of ozone would — that there's
anything incorrect about the loss of ozone and the increase of UV.
That is extremely well understood.
Mr. Boehlert. Just a quick two-parter.
171
Should we be concerned with ozone depletion, even if we don't
know its full impact?
And do any of you dispute the assertion that man-made chemi-
cals contribute to ozone depletion? Anyone dispute the second part
of it?
Dr. Albritton. As far as I can tell from the involvement in sci-
entific conferences, following the literature that was cited earlier,
participating in these assessments, the practicing ozone research
community believes that if CFCs were to continue to increase in
the atmosphere, that stratospheric ozone layer would continue to
deplete.
Mr. BOEHLERT. I was talking about our side when Dr. Ehlers left.
Dr. Olver over there is a scientist, too.
What about the first part of the question? Should we be con-
cerned with ozone depletion, even if we don't know its precise im-
pact?
Dr. Watson. I think the answer is, yes, sir. And that's the way
I think most of these documents are written, and that is, we do not
know all of the implications of ozone depletion, but we know some.
As the two medical experts on this panel have said, and the
international scientific community has said, if there's an increase
in ultra-violet radiation, we will certainly see an increase in non-
melanoma skin cancer.
While only a half to one percent of those cases are fatal, it is still
a very serious human health issue. There are costs associated with
that nonmelanoma skin cancer and, indeed, unfortunately, a num-
ber of such people do die.
So that we know quite well.
So even with that information alone, we can say it's a human
health issue.
With respect to other issues, such as the effects on food, natural
terrestrial eco-systems, suppression of immune system, there are
indications that there would be adverse effects.
My personal belief would be, even if we only knew ozone led to
an increase in nonmelanoma skin cancer, with some level of fatali-
ties, that in itself is enough to be concerned about, and all of these
other factors, such as suppression immune response system, mela-
noma, impacts on the ecological system, would make it further an
issue to be concerned about.
Mr. BoEHLERT. Dr. Singer.
Dr. Singer. I'd like to explain why I disagree.
You cannot tell from any evidence we have how much
nonmelanoma skin cancer is produced by a change in ozone.
I know that Dr. Watson claims that if UV increases by one per-
cent, then skin cancer will increase by two percent.
That number cannot be maintained, in my view. It is not correct.
Ill explain why that is so.
The clue comes from the fact that skin cancers of all sorts have
been increasing for the last 60 years. It has nothing to do with
changes in UV, nothing to do with changes in ozone. It has, as Dr.
Setlow correctly pointed out, it has a lot to do with change in life-
style.
People expose themselves more to the sun than they did many
decades ago. That's the clue.
172
And now, specifically, when Dr. Watson mentions that the skin
cancer rate, the nonmelanoma skin cancer rate, is five times great-
er in Albuquerque than in Seattle, and uses this as a way of get-
ting at the numerical value, I can show you that he's wrong on two
counts.
In the first place, this bill has a built-in assumption which as-
sumes that you have as many clear days in Seattle as you do in
Albuquerque.
That's not a valid assumption.
The second assumption is that people in Albuquerque or New
Mexico and Arizona wear raincoats all the time, like they do in Se-
attle, and cover themselves.
That's not true, either.
There's more exposure to the sun in warmer climates. And that
fact alone can explain a great deal of the increase in skin cancer.
We don't know how much of it. But, certainly, from the historical
evidence, I would say a great deal of it.
Mr. ROHRABACHER. Dr. Singer, with that, we will have to break.
We will recess for just about 10 minutes. We'll come back for about
10 more minutes of questioning for the panel, and then we will
break for lunch before the next panel.
So thank you very much. We are in recess for 10 minutes.
[Recess,]
Mr. ROHRABACHER. I call this hearing into order again.
Seeing that none of my fellow members are here at this point,
I will just move forward some questions. As I say, as we finish this
round of questioning, we will break for half an hour for lunch and
then have the second panel.
First of all, I have a series of questions that I'd like to ask.
One thing, some of the questions early on, and some of the testi-
mony earlier brought up some questions.
First of all, I guess I should ask Dr. Albritton this. When Dr.
Baliunas suggested that when we were talking about measuring
and trying to determine depletion of ozone, that you were using as
your benchmarks the highest year of ozone — a year where you had
the highest level of ozone.
Now, perhaps you could — and by the way, I understand how you
can use charts to prove things. And if you do that, doesn't that
skew the whole chart? And is that the case? And does that skew
your findings?
Dr. Albritton. Mr. Chairman, we actually did a different ap-
proach than what was described here.
We had no single one starting point on the downward trend. We
actually included the previous years as the baseline to determine
that starting point. And that way you don't unduly weight it with
any one starting point.
In the report back on this, we examined the sensitivity of choos-
ing the year in which the downward trend may have started. And
it is a relatively small sensitivity because of the point that I men-
tioned; namely, we're fitting with a curve that looks very much like
a hockey stick where there is a level period and then a linear
trend.
That decreases any weight on a starting point.
Thank you.
173
Mr. ROHRABACHER. Well, is it possible that — let me ask you this.
Is it possible that we could have had ozone holes in the Antarctic
or elsewhere in the world in the many, many hundreds or millions
of years that the earth has been around, before?
Dr. Albritton. All the evidence obtained from direct measure-
ments over Antarctica is that it requires elevated levels of chlorine
and bromine to cause the ozone hole that we observe now.
Indeed, the early part of the monitoring record in Antarctica, one
saw variations that were limited to the natural variations that one
sees in ozone in that area. And it was roughly in the 1980s that
the observational records showed the overall downward trend.
So I would take from that that without elevated chlorine in the
past, that would not have occurred, what we see now.
Mr. ROHRABACHER. So there weren't ozone holes in the past.
Dr. Albritton. No, sir.
Mr. ROHRABACHER, Is that accepted by the panel? I'm not sure.
Yes, sir. Dr. Singer?
Dr. Singer. I don't accept this statement. I published on it in
EOS, as a matter of fact, in 1988.
My view is as follows. It's very different from the one just pre-
sented and differs from the view presented by Watson.
The hypothesis I have is that chlorine is in fact the agent that
affects ozone, but only in the presence of the ice particles. And I
think this is supported by the present evidence.
Now what does it take to make ice particles? It takes water
vapor and a low temperature.
Therefore, if we had had in the past, and we have a long past
on this earth, several billion years, if we'd had in the past a cli-
matic situation that gave you very low temperatures and water
vapor in the stratosphere, I think you would have had ozone holes.
And by the same token, if the stratosphere should not warm up,
or if the water vapor content of the stratosphere would go down,
the ozone hole would disappear, even if we have chlorine in the
stratosphere.
That is the view that I have. It's a hypothesis. It should be test-
ed.
Mr. ROHRABACHER. Dr. Watson, would you like to comment on
that?
Dr. Watson. Thank you. Dr. Singer is obviously absolutely cor-
rect. You must have ice crystals.
There was enough water vapor and ice crystals back in the last
20 or 30 years. But there's something much more important. You
have to have chlorine. You need a specific amount of chlorine.
What we've done is we've not only looked in the laboratory.
We've measured in the field exactly the concentrations of the chlo-
rine.
The amounts of chlorine pre-Antarctic ozone hole, pre-human ac-
tivities, was only about six-tenths of a part per billion, not enough
to cause the observed change.
So you need cold temperatures and you need the elevated levels
of chlorine that have been put in there by human activities.
It can very, very easily be demonstrated. In fact, I would abso-
lutely welcome a paper by Dr. Singer to be peer-reviewed by the
scientific audience.
174
Mr. ROHRABACHER. Earlier on, when we were talking about — I
guess what I'm tr5dng to get at is whether or not the ozone is pos-
sibly a naturally occurring phenomenon that could have been — ^we
do know that it's cyclical within the year because we've seen that
some times of the year it's bigger, and other times of the year, it
almost disappears, if not disappears altogether.
There's something natural going on here as well. Don't the natu-
ral occurrences have something to do with this, as well as simply
what mankind is involved with?
And I'll open that up to the panel. Maybe first, Dr. Albritton, or
Dr. Singer, either one.
Dr. Albritton. Yes, thank you. Ozone is a naturally-occurring
compound. It's made by the sun's rays and it was removed over its
million original years by natural chemical processes.
And so the balance of the ozone layer that has existed ever since
we've had an atmosphere is a balance between the solar input like
the water coming into the bathtub, and natural chemical processes
that drain it away.
That level does fluctuate. It fluctuates because the natural proc-
esses fluctuate.
For example, it fluctuates with the intensity of the sun. It fluc-
tuates with the intensity of the removing chemicals.
We've observed the level of that fluctuation. That level of fluctua-
tion is much smaller than the general downward trend that we've
seen in ozone over the 1980s.
What we've done is we've taken a natural chemical cycle like
chlorine and we've augmented the amount of chlorine in the atmos-
phere, so it's like enlarging the hole at the bottom of the bathtub.
With the same input, the water level tends to gradually go down,
superimposed on that natural fluctuation as it goes down.
Mr. ROHRABACHER. The CFCs that are produced here, I take it
what you're sajdng is that the CFCs that are produced here have
the impact on the Arctic ozone hole.
Why is it that we don't have them creating the ozone hole over
the northern hemisphere?
Dr. Albritton. That's a very good question.
Mr. ROHRABACHER. Do the CFCs do that here?
Dr. Albritton. Why does the ozone hole appear over the south-
ern hemisphere and not exactly in the same manner over the
northern hemisphere?
Mr. ROHRABACHER. Right. And do our CFCs contribute to the
ozone hole there?
Dr. Albritton. Yes, sir. CFCs having a very long lifetime are
distributed all over the globe.
Mr. ROHRABACHER. Okay.
Dr. Albritton. It's the special nature of our planet being asjnn-
metric in the way the land masses are distributed.
Over Antarctica, you have a continent. You have a high-elevation
continent. You have it surrounded entirely by oceans, which iso-
lates this area and lets it be the coldest of the two poles.
So, in brief, the reason that the large number of ice particles
form in the stratosphere over Antarctica is that that is a colder end
of the planet than the north.
175
The reason the north is warmer is all of our land masses, with
their mountains, are in the northern hemisphere. And so the dy-
namics of the air bouncing off those mountains make the Arctic a
lot warmer place.
Mr. ROHRABACHER. So that global warming, if it's true, is going
to solve this problem for us.
Is that what we can conclude?
Dr. Watson. Mr. Chairman, unfortunately, it's exactly the oppo-
site of that. [Laughter.]
The carbon dioxide that we put into the atmosphere is predicted
to warm the lower part of the atmosphere. It's actually part of
Fred's thesis that it is that CO2 that's cooling the lower strato-
sphere.
So, actually, more carbon dioxide would make this problem
worse.
Mr. ROHRABACHER. All right. I was being a little facetious there,
I'll have to admit.
Dr. Singer.
Dr. Singer. Mr. Chairman, you asked the other question, which
is why do people count ozone depletion from the year 1970, when
it was the maximum?
Obviously, if you did that, you'd always get a decrease.
What we have to do in order to — let me say, I don't accept the
idea of ozone depletion, as yet. I'm not convinced that the present
data conclusively demonstrate it, and I'll explain why.
The natural variations are very large and you have to remove the
natural variations, stick to the 11-year solar cycle in the record, be-
fore you can decide whether or not there is really a trend, a long-
term trend.
It's a very simple problem. It's a very difficult problem to do.
In my view, you cannot do this if the record is very short. You
cannot do this if the record is only two or three solar cycles. You
have to have a longer record.
Unfortunately, to get a longer record takes time. You can't hurry
the situation. Even if you throw money at it, you can't speed it up.
I know that this is something that we'll do.
But now let me tell you what happened. The ozone trends panel
came up, as Dr. Watson reports, and Albritton reports, with their
story in 1988. At the same time, an independent team of scientists
working at Allied Signal, if that's correct, did an independent anal-
ysis. Their names are Hill and Bishop.
They published their analysis in a preprint, which I have. This
preprint showed, and I believe I quote them correctly because I had
long discussions with them. But even if you try to take out the nat-
ural variations, the so-called trend still depends on when you start
and when you stop. It depends on your selection of time interval.
And then something very curious happened. They published their
work finally in a peer-reviewed, refereed journal, together with
some other scientists, some of whom were government scientists.
And suddenly, that part of their work disappeared. It was never
mentioned again.
Mr. ROHRABACHER. It was lost in the ozone hole. [Laughter.]
Dr. Singer. Something like that.
Mr. ROHRABACHER. Dr. Watson, go right ahead.
176
Dr. Watson. If Dr. Albritton could actually hold — in the silver
document there, the Bishop data is actually in there with Bill Hill.
He actually does a sensitivity analysis of taking out the solar cycle,
the seasonal cycle.
It also shows the sensitivity to changing the starting point.
It did not disappear. It's actually in the international assess-
ments. And as Dr. Albritton said earlier, it's a relatively small ef-
fect.
In other words, you broadly get the same effect, whether you
start in 1965 or 1975.
Allied was extremely concerned about that. At that time they
were the second largest producer of CFCs in the world. They did
not want to phase them out.
Their own analysis showed that there's some sensitivity, but it's
small.
Mr. ROHRABACHER. I would hope after the hearing today, you
folks could maybe go into that document and apparently Dr. Singer
thinks there's something that's not there and you believe some-
thing is there, and you can determine that for yourself.
Dr. Singer. This is not a peer-reviewed document. This is not a
publication that has been mentioned by Congressman Rivers as a
peer-reviewed journal.
In the peer-reviewed journal, the Journal for Geophysical Re-
search, Hill and Bishop don't mention this, the fact that the trend
depends very strongly, I think — it's a matter of judgment — ^very
strongly on when you start and when you stop, on the selection of
time interval.
Let me also mention
Mr. ROHRABACHER. Before we get stuck on this one issue.
Dr. Singer [continuing]. Allied Signal is now the largest manu-
facturer of CFC substitutes.
Mr. ROHRABACHER. And before we get stuck in this one area,
we'll let Dr. Albritton have one last thing, and I have a couple
more questions. And we'll move on to Members of the Committee
who have not had a chance to ask, and then some other Members
who have some other questions.
Dr. Albritton. Just a tiny footnote to end that discussion.
Mr. ROHRABACHER. Yes.
Dr. Albritton. Dr. Lane Bishop is a lead author on the current
chapter of the ozone trends panel here.
Mr. ROHRABACHER. All right. And we'll talk about that later.
Now, Dr. Albritton and Dr. Watson, you both refer to the Mon-
treal Protocol as effective. And in fact, during your testimony, Dr.
Watson, you actually said — well, this can only be calculated as to
what if we didn't have it? This is going to be the results that would
have been detrimental.
What are Russia, China, and India, the three countries that rep-
resent a majority of the world's population, doing to carry out the
Montreal Protocol?
Dr. Watson. India and China also have to follow the same
phase-out schedule as the developed world, but with a ten-year lag.
They have agreed at the international forum that they will also
phaseout.
177
They also, however, need technical and financial help to phase
out. That's why there's something called the Montreal Protocol
Trust Fund, of which the United States contributes about 25 per-
cent, which unfortunately this Congress decided to eliminate in the
President's budget.
My view is India, China, and Russia will all follow the inter-
national obligations and phase out the CFCs, assuming there is in-
deed financial and technical support to help them.
Mr. ROHRABACHER. But they're not now, and they're having no
impact at all in those countries, right?
Those countries are still operating — their activities have not been
altered because of the protocol. Isn't that correct?
Dr. Watson. The activities in Russia have been altered and the
activities in India and China, they are following what they signed
up for. That is, a complete phaseout, like us, ten years after us.
Mr. ROHRABACHER. Well, what about reports that these countries
are becoming the source of actually manufacturing more CFCs and
involvement in a huge black market that's been developing all over
the free world right now?
Dr. Watson. I honestly cannot address that. But, hopefully, you
could maybe address that to the next panel, which may have got
more expertise on that subject.
It's just outside my expertise.
Mr. ROHRABACHER. All right. That's a fine suggestion.
Let me just ask this. If people were allowed to keep freon in their
air conditioners, as was planned until the year 2000, and we didn't
speed up this situation, as we did because of — and I might add, the
stampede created by a political leader and group of political people
who, I think, created a false alarm, what would be the difference
today in the world's ozone layer?
Dr. Albritton. We made an estimate of that using the same
techniques that were done for the international assessment. And
let me rephrase your question slightly.
It would be impossible to go backward to the early 1987 levels
because measures have already been done to reduce those.
But we calculate that if one were to continue at the 1995 present
emission levels up to the year 2000, and that is, delay that phase-
out, that in terms of the total amount of ozone that will be lost be-
tween now and, say, the middle of the next century, it would add
five percent more loss total to that ozone.
That would be a 20-year period where the ozone depletion would
be approximately one percent higher, and others can translate that
into the health effects.
Mr. ROHRABACHER. So it would be one percent higher if we
wouldn't have moved forward.
Dr. Albritton. The total effect of delaying it that 5 years is to
add 5 percent more ozone depletion over the next 50 years.
Mr. ROHRABACHER. But where was the 1 percent, again?
Dr. Albritton. The actual year-by-year ozone decrease in the
next 20 years would be one percent more than we had anticipated.
Mr. ROHRABACHER. And do we see any major health impacts
from that?
Dr. Kripke. Well, according to the 1994 assessment, there were
some calculations made about what happens to skin cancer inci-
178
dence, nonmelanoma skin cancer incidence, under several different
scenEU'ios of phase-out.
It shows that, with the Copenhagen Amendment to the Montreal
Protocol, which is the current scenario that we are operating
under, that even under the best conditions, which these represent,
there will still be a 25-percent increase in nonmelanoma skin can-
cer in the year 2050, in comparison to what it was in 1980.
And this is at approximately 50 degrees north latitude.
So even under the very best scenario of phaseout, there will be
more cases of skin cancer than there were before.
So I think there's no question that decreasing the rate of phase-
out will have an impact, a significant impact on nonmelanoma skin
cancer.
Mr. ROHRABACHER. We'll let the next panel decide whether or
not, and we'll talk about the costs that were related to speeding
this up, and whether or not the number of skin cancer cases and
the cost related to skin cancer cases would sometimes, if treated
early on, are negligible costs. And sometimes if they're not treated
early on, are somewhat expensive.
Dr. Kripke. May I respond to that, please, Mr. Chairman?
Mr. ROHRABACHER. Not until I finish the statement. Then you're
very welcome to respond.
And that is, compared to the billions of dollars that are taken out
of our economy by the decision to speed this up — there is an im-
pact.
For example, earlier, you were complaining that we didn't have
money for the research of certain diseases. Well, that money is
coming out of the same pot that's disappearing because we sped up
the process.
This is all coming out of the same economy.
And if money is not absolutely necessary to spend the money,
and it costs us, let's say, $20 billion out of our system, or some peo-
ple would estimate it at much higher levels, the cost of speeding
this up, that money is now not available for education, for health
care, for the research that you support.
And please do comment on that.
Dr. Kripke. I think one misconception, one popular misconcep-
tion needs to be set straight for the record. Which is that it's not
true that a delay in seeking treatment for nonmelanoma skin can-
cer is responsible for increased economic costs.
There are many cases of nonmelanoma skin cancer which are le-
thal, which are aggressive, which are invasive.
We happen to have a particularly high incidence of such cancers
in the State of Texas. And it is not true that these skin cancers
are aggressive, disfiguring and life-threatening because there is a
delay in seeking treatment.
That is a misconception.
Mr. ROHRABACHER. You mean, in other words, some people who
don't seek treatment earlier would go through the same problem,
anyway. It's just something out of control.
Dr. Kripke. That is correct. Clearly, early diagnosis is very im-
portant for skin cancer and for getting treatment. But it is not true
that early diagnosis will prevent all serious cases of nonmelanoma
skin cancer.
179
Mr. ROHRABACHER. I don't think I used the word, prevent. I don't
think that ever came up until this moment. j
Dr. Kripke. The other point I'd Uke to make is that
nonmelanoma skin cancer has a significant economic and psychp?
logical burden as well.
It is not as life-threatening as melanoma skin cancers, as we all
know. But nonmelanoma skin cancer is a serious disease. If any of
you have had it, you will know that it can be cosmetically disfigur-
ing. It occurs
Mr. ROHRABACHER. Would you, then, and as my staff member
recommends, which is a good question, would you then recommend
that people not move from the northern part of the United States
to more central United States or southern United States, in order
to — because the risk is just too high?
Dr. Kripke. I wouldn't recommend anything. I don't recommend
people where they should live.
Mr. ROHRABACHER. You've been recommending something all
day. I mean, the fact is you're here to testify about risks. But
you're not willing to tell someone because of the increased — it
sounds like to me you're saying the increased risk is dramatic. But
yet, that increased risk, as we've heard in earlier testimony, is in-
creased as much as moving from one part of the country to the
other.
You don't think that we can then recommend people not to move
from Maine to Florida?
Ms. Rivers. Mr. Chairman, would you yield for a moment?
Mr. ROHRABACHER. Not until the question is answered. Thank
you.
Dr. Kripke. I think we can recommend that if people do move
from Maine to Florida, that they need to try to protect themselves
from the increased ultra-violet radiation that they will undoubtedly
experience. Just as we will have to try to tell people to protect
themselves from increases in UV-B radiation that are caused by
ozone depletion.
Mr. ROHRABACHER. Did you see this report that I have here, and
it's from the American Journal of Public Health? It was reported
in 1995, it says.
It's a study in Chile, in fact, of southern Chile, that says that the
study does not support existing lay reports that, basically, the
ozone hole is causing any more cancer.
Have you seen this report?
Dr. Kripke. Yes, I'm aware of that study. And that study refers
specifically to the ozone hole over the Antarctic.
You will be aware that there were originally some reports in the
news media of cataracts in rabbits and all kinds of bizarre health
effects that were possibly attributed to the ozone hole over the Ant-
arctic.
There has been no scientific substantiation of those claims based
on the study that you're quoting.
That does not mean that IJV-B radiation does not cause skin
cancer.
Mr. ROHRABACHER. I believe that — maybe you could draw that a
little bit closer to me, the relationship there.
180
I thought that the depletion of the ozone, like the ozone hole, was
what was going to cause us to have more of that.
Dr. Setlow. But skin cancer results from a chronic exposure
over many years to sunlight. The ozone hole has not been with us
for a terribly long time. And it isn't there for most of the year.
So the fact that there's an ozone hole does say that there's going
to be more ultra-violet than usual. But, of course, the amount of
ultra-violet isn't very great in those few months.
And so it's a question of the integrated exposure, not the instan-
taneous exposure, that gives rise to skin cancer.
Mr. ROHRABACHER. So, in the long run, it will happen.
Ms. Rivers. Mr. Chair? That's what I was seeking recognition on
earlier because I've heard this argument get put forward a couple
of times about, it's the same as moving 60 miles south.
But my understanding of it is that the ozone layer would be de-
pleted at a rate of 3 to 4 percent. And so, when you look at
compounded effects over time, that the risk gets larger and larger
and larger.
Is that a correct assessment. Dr. Watson?
Dr. Watson. Because of the international regulations, the Mon-
treal Protocol — and we do need all countries to obey the Montreal
Protocol — ^we believe ozone depletion will finally peak, maximize
about 7 percent less over mid-latitudes in summer than what it
was, say, in 1970.
The effect that 7-percent ozone depletion will not be an instanta-
neous rise in the number of skin cancer cases. It's the chronic expo-
sure, as both Margaret Kripke and Dr. Setlow have said.
We will see the effect of ozone depletion today in 20, 30, 40 years
ahead. And so, we will expect to see those increases in the future,
not today.
Mr. RoHRABACHER. However, you did say earlier in your testi-
mony, had we not gone forward with the Montreal Protocol, that
things would have been a lot worse. And that sort of doesn't coin-
cide with what you just said.
Dr. Watson. I think it does, sir. What I mean is, because of the
Montreal Protocol, we've managed to limit ozone depletion to only
seven or eight percent.
Without the Montreal Protocol, we would probably in the future
be looking at ozone depletions of 10, 20, even 30 percent.
Mr. RoHRABACHER. But in the earlier testimony, you did mention
some health impact. I don't have it right on the top of my head
now, but I remember you mentioning that.
Dr. Watson. I think after you read it carefully, sir, you'll find
it is consistent.
Mr. ROHRABACHER. All right. Thank you very much.
I'd now like to call on the distinguished former Chairman of the
Science Committee, Congressman Brown.
If you have any questions for the panel, please feel free.
Mr. Brown. I apologize first to the panel because I haven't been
able to be present this morning. We're having a mark-up in an-
other committee and I will be required to leave again shortly for
a vote in that committee.
But as I said this morning, I wanted to compliment the Chair-
man on arranging for this hearing. I think it will do a great deal
181
to enlighten the public on some of the factors involved and action
on these long-term potential environmental threats. And also on
the scientific processes involved.
And I want to commend the witnesses for the job that they have
done.
Let me suggest just a couple of questions. One, I gathered the
impression here earlier that the Chairman perhaps was suggesting
that the speed-up in action taken in 1992 to phase out CFCs might
have been due to some hysteria created by careless politicians rais-
ing the threat of tragedy striking or something of that sort.
Was there any such relationship between the 1992 action and
any political propaganda that may have been issued around that
time that may have been favorable to an earlier phase-out?
Dr. Watson.
Dr. Watson. If I could answer that, sir. Several people have
mentioned the NASA press statement that was made in February
of 1992.
The statement that was made was absolutely correct, and indeed,
as it was followed on by then- Senator Al Grore was correct. If the
conditions, meteorological conditions, had continued, there would
have been a significant loss of ozone over Kennebunkport.
It was a prediction with all the right caveats.
I personally believe that had no effect on the international nego-
tiations, for a very simple reason. As was also stated by April of
that year, there had been not a retraction, but a clarification of the
situation. The clarification was that there was no ozone hole over
Kennebunkport because the meteorological conditions changed.
Now the Copenhagen Amendments were signed in November of
1992, a full eight months after even the so-called retraction by
NASA. The Senate in this country, in a very bipartisan manner,
didn't ratify that until a full year after that situation.
So, in my view, Mr. Chairman, the reasons that the Copenhagen
Amendments were so forcefully pushed through internationally —
who don't care about NASA press statements — and within the Sen-
ate, was they observed that we by now had seen global ozone deple-
tion at all seasons, except for the tropics. And it was that informa-
tion that pushed the amendments to the Montread Protocol.
Mr. Brown. Do any of the other witnesses wish to contradict or
add to that?
I pointed out this morning that the habit of politicians of making
what might be fairly outrageous statements is not confined to the
vice president or to any other single politician.
I do it myself, on occasion. [Laughter.]
Dr. Singer. I think I would like to make a short statement to
balance or put into perspective what Dr. Watson just said.
What brings me into this whole question that we're discussing
today is this deplorable way in which policy is being made by press
release.
Mr. Brown. Yes.
Dr. Singer. And I think this is very, very bad. Very bad. It pre-
vents and precludes the careful examination of the evidence and it
will lead us, I think, into situations that are extremely costly, into
hasty actions that are unjustified by scientific evidence.
In my testimony, I give a large number of examples.
182
Right now, for example, this week, we're faced with a press re-
lease from the World Meteorological Organization by a well-known
ozone activist who tells us that the ozone hole this year is going
to be worse than it's ever been.
How does he know that? Well, he's only seen it for the first few
days.
But we have, fortunately, some balance in this. A NASA scientist
has said, this is not true — Paul Newman.
It's in my testimony.
Another scientist in Australia has said, it's impossible at this
stage to predict what the eventual ozone hole would be like. It may
well be worse than it was last year, or it may be less.
But it illustrates how press releases are being used — or misused,
I should say — to force all kinds of political action that may be
harmful to our economy.
Mr. Brown. Well, Dr. Singer, let me say that I agree thoroughly
with the principle that you've espoused. I don't believe in policy
being made by press release, either.
Did you want to respond to that, Dr. Watson?
Dr. Watson. Yes, because I would also like to concur that we
should not make policy by press release. I want to add just one
more thing.
President Bush obviously was the President that for the United
States made the decision to negotiate the Copenhagen Amend-
ments.
He did not, I'm quite convinced, look at the NASA press release.
Alan Bromley was his science advisor at the time and Alan
Bromley took advice from a large number of people and discounted
that press release.
So I do not believe we or President Bush made policy by looking
at a press release.
Mr. Brown. Well, the general principle is sound, that we
shouldn't. And we've seen that in many, many situations.
I was very disturbed, serving on the agriculture committee, when
I saw the first press releases about the bad effect of Alar on apples.
There is some underlying basis for being worried about Alar. But
there was no basis for assuming that there would be an epidemic
of cancer in children because of what we were doing. And yet, the
press releases would seem to indicate that.
This bears out your point.
Now let me say in defense of politicians, that it's sometimes very
difficult to convey to the public a true sense of a very complex situ-
ation. And that happens to be true in the case of ozone.
It is illustrated by a couple of charts which I'd like to raise a
question about now.
Dr. Watson, you have in your testimony a chart labelled Figure
4, which says, global ozone trend — 60 degrees south of 60 degrees
north. And it seems to indicate a substantial decreasing trend in
ozone.
Dr. Baliunas, you have a chart labelled Chart 2, northern hemi-
sphere ozone, which seems to show no trend in terms of any de-
crease in ozone.
And at the first blush, the two charts would seem to be con-
tradictory. And yet, I note, Dr. Baliunas, that your chart says only
183
northern hemisphere ozone and it's measured in some abstruse
unit which I've never heard of, Dobson units. And it extends from
1955 to 1990.
Dr. Watson, your chart only extends from 1975 to 1994. It is not
measured in the same abstruse unit. Apparently the chart shows
percent deviation from monthly average.
Now, I ask you, is the apparent contradiction in what these two
charts seem to say real or not?
Dr. Baliunas. There's several factors to note in this Chart 1 and
Chart 2, which were the same data.
Mr. Brown. And I'm using this to illustrate the point that some
of these things are difficult to convey to the public.
Dr. Baliunas. Yes. These are ground-based data from the north-
ern hemisphere ozone, slightly different from the data in Dr. Wat-
son's testimony.
Mr. Brown. Which eQso includes southern hemisphere.
Dr. Baliunas. Which also includes southern hemisphere. The
northern hemisphere data that I show from the ground-based sta-
tions agrees where the satellite data overlap with it in those re-
gions.
And the data I show here in Chart 1 and Chart 2 have been cor-
rected for the spring to fall seasonal change, but no other effect. It
hasn't been corrected for the solar effect. It hasn't been corrected
for the QBO, and it has not been corrected for any other volcano
impact.
Dr. Watson's chart I believe does correct for those. So there's not
real contradiction. It's just that he's charting it to show the trend.
I was showing some of the natural variability.
So two different aspects.
Mr. Brown. But your chart does not show as much, what looks
like variability, as his chart does.
Dr. Baliunas. Well, if you look at the percent change, my Chart
1, which is the same as Chart 2, I still have a lot of natural varia-
bility, but there is a trend in the latter part of the data that would
be reflected in his.
Mr. Brown. I see, yes.
Dr. Baliunas. If I were to correct everything out, Chart 2 is the
same data, but on an absolute scale in terms of these Dobson units,
which is the amount of ozone in the column.
Mr. Brown. Did you wish to comment, Dr. Watson, about that?
Dr. Watson. Yes.
Mr. Brown. And I'm looking for guidance as to how we can con-
vey this kind of information to a public who doesn't understand
these things.
Dr. Watson. Exactly. What the scientists wanted to portray in
my Figure 4, which is this from the International Ozone Assess-
ment— it's not my work, personally--was to try and show what
were the effects of human interactions on the ozone there.
They took the ozone record from both satellite and from ground-
based stations and they then took out seasonal fluctuations. They
took out the effect of what we call the quasi-biannual oscillation.
That's changes in the weather patterns every two years. And they
took out the seasonal cycle.
So you could take out the natural effects on the ozone there.
184
What you have left is that trend £ind what one can clearly see,
there was approximately a 5-percent ozone depletion between 1979
and 1994.
If you actually just flip over the page to my Figure 5, you can
actually see how it is very sensitive to latitude. There is no change
in the tropics independent of season, and you have a large change,
larger change, as you move to the mid- and higher latitudes of both
the northern and southern hemisphere.
So in the ozone assessment, we try to get the information most
relevant to policymakers. We try to separate out the long-term
trend.
That has nothing to do with natural variability.
Mr. Brown. All right. I thank you for that explanation.
Incidentally, do either of the charts, or do any of you, find vari-
ation here that coincides with the 11- or 12- or 13-year sunspot
cycle?
Does that have any bearing on this?
Dr. Baliunas. Well, all charts of this sort respond to the 11-year
cycle. It's the solar ultra-violet flux that has to do with this.
Mr. Brown. Yes.
Dr. Baliunas. The ultra-violet flux is not directly measured, un-
fortunately, over this entire interval and has to be determined by
proxy.
Mr. Brown. Well, I appreciate this explanation. I think it's help-
ful to me.
I apologize again for not being able to spend more time with you.
I would enjoy it very much. And I thank you, Mr. Chairman.
Mr. Rohrabacher. I'll have to say that we've had a long panel
here. I'm hungry, myself. I haven't had anything to eat today.
Mr. Olver. I'm quite willing to go without lunch for about 5
more minutes.
Mr. Rohrabacher. Out of courtesy to my colleague, I will go for-
ward with another 5 minutes. But let me note just one thing before
we go into the last round of questioning, then.
Ajad that is, caveats — I believe that caveats sometimes are not
properly used. And I know that you've got to say that this is what
I believe, except, or could be or may be, and all this.
When I was a journalist, every time I hear people using caveats,
usually, and I'm not claiming this of this panel at all, but usually,
caveats are used to create misimpressions.
I would just warn the panel and warn the Members of the Com-
mittee, et cetera, that caveats, we should be very skeptical when
caveats are used.
Admittedly, when you're trying to be honest about it, it might
prove just the opposite, meaning that some caveats are used be-
cause someone realizes that someone on the other side might be
correct and there might be some avenue there that you're leaving
yourself open to an honest discussion.
That's one thought.
And the other thing. In terms of whether or not the political mis-
use of certain information created policy in terms of what the ozone
hole was going to do over the northern hemisphere, one need only
to say, look at the vote that took place after Mr. Gore's presen-
tation before this Committee and for his speeches.
185
It was a vote of 96 to zero. And I'm sure that there were many
Republicans that were rather skeptical before. But Mr. Gore up
there saying, absolutely, there was going to be this ozone hole, I
bet there was a caveat in there somewhere that probably made it
clear that it wasn't absolute, but it just sounded like he was saying
it was absolutely going to happen.
There were a lot of Republicans that were skeptical who went
right along with it. And what happened was that the ozone hole
failed to materialize.
That's really what we're talking about here. If we're going to
make policy, let's make it based on things that are real.
And one last thing before we let Mr. Olver have his 5 minutes
of questioning. And that is, one of the other things that we have
to have in order to determine policy is a free and open discussion.
And perhaps the most disturbing thing that's come out of this
hearing is not whether or not caveats are being used and whether
people disagree on this. But instead, what Dr. Baliunas has stated
very clearly for the record is that there was an attempt to stifle her
discussion of this issue.
Now all over the United States, we've heard talk about what's
politically correct and politically incorrect and heard about there
are certain forces in our society that are intolerant of disagree-
ment.
When we start hearing reports that distinguished scientists and
the people who are looking into an issue like this have had threats
that they shouldn't come and testify, or that they shouldn't partici-
pate in the discussion of an issue, this is very serious. And perhaps
that's the most serious thing that came out of this hearing today.
I plan to follow through with Dr. Baliunas on this, and I will be
contacting directly those groups within government, and outside of
government as well, that think that they can try to stifle discussion
on issues like this.
Ms. Rivers. Mr. Chair, can we make sure that the findings —
first, the accusations and the findings are a part of the official
record so that since this was raised in the course of this discussion,
it will be on the record for Congress and the American people?
Mr. Rohrabacher. Would you submit for the record a letter de-
tailing efforts that have been made, that you believe were made on
this issue, not just for this hearing, but over your discussion of this
issue, that you've seen where groups inside government and out-
side government have tried to stifle discussion of this issue?
Dr. Baliunas. I will.
Mr. Rohrabacher. So we can expect that.
Ms. Rivers. And please, specificity is important in these kinds
of accusations.
Mr. Rohrabacher. That's correct.
Ms. Rivers. Dr. Watson.
Dr. Watson. Yes, Mr. Chairman. I view that as one of the most
serious things I've heard today. I know this Administration would
certainly like to know of any wrong-doing by any federal employee
who has tried in any way to threaten or coerce Dr. Baliunas.
So we would like, through you, Mr. Chairman, that when infor-
mation, written information, is documented, is sent to you, I cer-
186
tainly will take this to the President's science advisors and other
relevant people in the Administration.
Mr. ROHRABACHER. We will do a preliminary investigation of
this, and I can tell you that if we find there to be validity to this
charge, that there will be another hearing and we will have people
called before this Committee and put under oath to see what
they're doing.
I can guarantee you that right now.
Mr. Olver, you've got 5 minutes while my stomach is growling.
Mr. Olver. Thank you very much, Mr. Chairman.
I was very grateful for the former Chairman's and Ranking
Member's discussion here. But I have been working in the same
kind of direction, trying to figure out — I've been looking, having
had a little bit more time to think about these graphs and so forth.
I'm still a bit puzzled. Let me ask a few quickies here.
Do we all agree on the scientific side of this panel, the atmos-
pheric side of the panel, at least, without the biological side, be-
cause I really want to talk about the ozone layer itself here, that
there is little seasonal variation in the tropics of ozone?
Is that relatively agreed? Okay. And may I use the tropics as 30
north to 30 south, or is that not a fair usage? Roughly. Roughly?
Okay.
All right. So if we agree that that is relatively nonseasonal, and
we also agree — let me see if this is true, that there is an agreement
on the part of the scientists that the ozone problem depletion oc-
curs more in the southern hemisphere around Antarctica because
that's where the ice crystals are. It's colder. Ice is necessary, along
with the chlorine or fluorine or bromine or something or other, in
there.
Is that also agreed on? Okay.
Now, if that's the case, then there is something really puzzling
about these two pieces of data. Even after one corrects, as the
Ranking Member had gone through, and recognizing that Dr.
Baliunas's data is only for — well, cover 50 years, 40 years, what-
ever. And the data on the part of Dr. Watson is really only 15
years.
So you're only looking at the eastern end of this data on the part
of Dr. Baliunas. And that's falling, where it looks only at the north-
ern hemisphere, which the 30 to 60 on the northern side, which is
less subject to the closeness to the great hole that appears season-
ally each year in the southern hemisphere. And yet, the percent-
ages that are being shown there are plus or minus only a few per-
cent. Even at its peaks it's zero and goes to minus four. Whereas,
the data that covers and averages across everjrthing, all four of
these sectors, from plus 60 to minus 60, is data that shows a trend
here going at the 6 percent level.
Which suggests, at least, that the corrections that Dr. Baliunas
has agreed have been made in the data, must be pretty dramatic
for that set of data to also be true.
If you follow that — I see some people sort of nodding roughly. So
the general thing.
If we've corrected for everything and haven't over-corrected and
so forth, then there's some pretty dramatic differences between
these two data, sets of data, as they have been put forward.
187
Now let me just follow with Dr. Singer for a minute.
I think I understand from what you saiid that you feel that one
should be considering several cycles, several sun cycles, solar cy-
cles, 11-year solar cycles. And we really only have data going back
maybe three cycles, while we've had CFCs.
I think the argument is that you can't yet tell whether CFCs,
CVCs, whatever, has had much effect on this because we haven't
been able to go back more than a couple of cycles while we were
producing these things.
Is that what I'm hearing?
Dr. Singer. You're partly correct, sir.
The reason we need a number of solar cycles has nothing to do
with CFCs, as such. It has to do with the fact that each solar cycle
is different from each other. The sunspot number in each cycle is
different.
Mr. Olver. Okay.
Dr. Singer. They're sort of sui generis. In other words, you can-
not
Mr. Olver, But you have said that the maximum ozone occurred
a couple of cycles ago and so ever3rthing obviously is going to go
downhill from that because that was maximum.
Dr. Singer. Yes, sir.
Mr. Olver. What is the nature of our data? You've said, yes, you
agree to that.
Dr. Singer. We have ground-based ozone data only since 1957.
Mr. Olver. So we've got three cycles' worth of ground-based
ozone data.
Dr. Singer. On a global scale, yes.
Mr. Olver. And before that, we don't know.
Dr. Singer. Before that, we have ozones
Mr. Olver. So how can you say that that was at a maximum at
the time that CFCs and so forth began to come in, if we don't have
that ground-based data in the first place?
Dr. Singer. Ground-based data on a global scale only started in
1957.
Mr. Olver. But then, how can you say that that was at a maxi-
mum at that time? Clearly, it's gone down since that time.
Dr. Singer. Actually, we have a record of global ozone, actually,
observation, since 1957. And according to the information pub-
lished, ozone showed a maximum in 1970 and then started to go
down.
Mr. Olver. Basically, three cycles.
Dr. Singer. The question is, is this due to solar effects or natural
changes, or is it due to CFCs?
Mr. Olver. But your comment, if I remember correctly, was that
you're not convinced that the ozone layer depletion has anything to
do with CFCs and it may be just natural phenomena that would
have been there is we looked back farther.
Dr. Singer. Yes.
Mr. Olver. If we looked back six or more cycles farther back,
that we would see a series of cycles along these lines.
Dr. Singer. Yes. And the reason I think so
Mr. Olver. Do you agree that the ozone layer, that the ozone
hole is expanding, is larger than it was some years ago?
188
Dr. Singer. That's an interesting question. Let me answer all of
these interesting questions, if I can.
Mr. ROHRABACHER. This will have to be the last question.
Dr. Singer. Starting with the ozone hole. The ozone hole, as I
mentioned before, was not predicted by the theory. This is why I'm
skeptical of the present theory.
The present theory cannot even predict what the hole will be like
next year, or 10 years from now, or 20 years from now. The reason
for this is that the hole is pretty much controlled by climate
changes and not by ozone concentration — sorry — ^by chlorine con-
centration at this stage.
The hole, as I mentioned before, is genuine. It's a transient phe-
nomenon.
Now the question of global ozone is quite different from the ques-
tion of the Antarctic hole. The question is what was the global
ozone like before 1957?
My answer is I wish we knew. But we do have some idea because
we have sunspot number observations and we know that ozone de-
pends on the sunspot number in some way. The more sunspots you
have, the more ozone you have in the atmosphere.
And that's why, since sunspots have an 11-year cycle, you see an
11-year cycle also in the ozone in the last 35 years.
Now, you may know that sunspots have varied tremendously
over the last two hundred years. There was a period of time around
1700 when there were no sunspots for many years, for some rea-
son. We don't know why.
Actually, Sallie Baliunas is probably a greater expert on this
than I am and will tell you that this is so.
And my supposition is that ozone should have varied by tremen-
dous amounts naturally because of these large natural variations
in sunspot number.
Mr. Olver. I have a feeling that I could understand this.
Mr. ROHRABACHER. That's the opposite feeling that I have.
[Laughter.]
As the Chairman, I'm going to use the Chairman's prerogative to
give Dr. Watson 30 seconds to summarize his reaction to that last
statement, out of fairness, and then to call a halt to this panel.
Dr. Watson. Two quick questions. Dr. Singer is right. We only
have about 30 years or three solar cycles of global ozone. We have
some individual stations like at Rosa that go back to 1930, six solar
cycles.
So when we've analyzed over six solar cycles
Mr. Olver. Where?
Dr. Watson. At Rosa in Switzerland. When we take that data
and all the satellite data and all the global ground-based data, we
tend to believe, based on a lot of analysis, that the maximum solar
variability is only 1 to 2 percent.
And yet, what we're observing in many latitudes is ozone deple-
tions of 5 to 10 percent.
So the solar variability is small compared to the observed trends.
Mr. Olver. It's a correction that you make.
Dr. Watson. It's a correction and it's taken into account in all
statistical analysis.
189
Mr. ROHRABACHER. With that, I'm sure that the transcript of this
hearing will be perused by people who have much greater depth of
understanding of these issues than the Chairman.
I want to thank each and every one of you. I appreciate your tes-
timony. I think this has been very thought-provoking. It's also
thought-provoking to people who are decision-makers and have
some scientific background.
I think we've accomplished something here today.
So thank you all for participating. I'm going to have lunch. We
will be back in one-half hour, which makes it 2:15, we'll reconvene.
We're in recess.
[Whereupon, at 1:45 p.m., the Subcommittee recessed, to recon-
vene at 2:15 p.m., of the same day.]
Afternoon Session
Mr. ROHRABACHER. I'd like to welcome all of you back and wel-
come the second panel for today.
I think that the last panel provided some very thought-provoking
intellectual confrontations. I was very pleased that we had the
issue for what I consider to be a high level of debate on a very im-
portant issue.
Our second panel consists of:
Mary D. Nichols, who serves as Assistant Administrator for Air
and Radiation at the Environmental Protection Agency;
Ben Lieberman, an environmental researcher, an environmental
researcher with the Competitive Enterprise Institute;
Kevin Fay is with the Alliance for Responsible Atmospheric Pol-
icy, an industry-sponsored organization;
Richard Stroup is an economics professor at Montana State Uni-
versity and a senior associate with the Policy Economy Research
Center in Montana, as well; and finally.
Dale Pollet. He is a project leader at the Louisiana Cooperative
Extension Service.
Jimmy Hayes is not here to introduce you, but he was schedule
to. So I am sure he is at a hearing, making his vote count.
So, Mr. Pollet, and the rest of you, I'd like to welcome you to the
hearing today.
I think we will then start off with Ms. Nichols.
STATEMENT OF THE HONORABLE MARY D. NICHOLS, ASSIST-
ANT ADMINISTRATOR FOR AIR AND RADIATION, UNITED
STATES ENVIRONMENTAL PROTECTION AGENCY, WASHING-
TON, DC
Ms. Nichols. Thank you, Mr. Chairman.
Mr. ROHRABACHER. And again, if we could do, as we did with the
first panel, try to look at 5 minutes and then we'll have some dis-
cussion between us afterwards.
Thank you.
Ms. Nichols. I'll do my best to summarize my summary of my
testimony.
I'd like to start off by saying, Mr. Chairman, that I believe that
the global phase-out of CFCs and other ozone-depleting chemicals
is a model of the proper relationship between science, economics,
and international diplomacy.
190
It rest on an overwhelming consensus within the community of
qualified scientists, economists, and business analysts.
The phase-out policy was developed under Presidents Reagsin
and Bush, with strong bipartisan support, and the Clinton Admin-
istration is proud to carry it forward to its completion.
In addition, it enjoys overwhelming international support with
150 nations having become parties to the Montreal Protocol.
And indeed, to the best of my knowledge, Mr. Chairman, this is
the only country in the world which is even considering the possi-
bility of altering the phase-out schedule.
Mr. Chairman, protecting the ozone layer should be a matter of
common ground. And I am puzzled and dismayed that, apparently,
it is not.
I am particularly concerned by Congressman DeLay's legislation
that would entirely repeal the ozone layer protection provisions of
the Clesin Air Act, as well as by Congressman Doolittle's proposal
which is only a little less drastic, to roll back the CFC phase-out
deadline to 2000.
I believe that these proposals would be disastrous, not only to the
ozone layer, but also to the health of the American people, because
they would exalt what I think have to be considered fringe views
on science and economics over the international scientific consen-
sus, as well as wreaking havoc in industries that have invested
very large sums of money, talent and effort to make a smooth tran-
sition away from CFCs.
They would also, of course, put the United States in violation of
the Montreal Protocol and break faith with the other nations of the
world that have been and are doing their part to protect the ozone
layer.
I've been asked to focus primarily on the decision that was made
in 1992, before my arrival here in Washington, to accelerate the
CFC phase-out deadline from 2000 to 1996.
And I'd just like to point out that the decision, I believe, having
looked at it again, was right at the time that it was made and is
even more clearly justified in retrospect today.
I'm not going to go through all of the arguments on the climate
issue. I think you heard a lot from the scientists this morning.
Rather simply to say, I'm not a scientist. I'm not here in that ca-
pacity. I'm a policy-maker and have been for many years in areas
that deal with science and environmental policy.
In making the decisions about implementing this program, I
need to rely on the work of scientists.
And I have to say that when you look at the list, such as the one
that's on that chart that's in front of you, of the international at-
mospheric chemists who have completed the review of the chem-
istry on ozone depletion for the United Nations's evaluation that
was most recently completed, and who signed on to the assessment
that supports the phase-out, on the one side, compared with the
list on the other side, I think it is compelling to a person in my
position.
I have been charged to act in defense of the environment, using
the best sound science at our disposal. I believe that, in that con-
text, numbers, or at least numbers of reports by people with the
appropriate credentials, do have to count.
191
Now, on the issue of the costs and the benefits of the phase-out,
and whether the health effects are justified, I'm sure you're going
to be hearing a lot more about that from others.
I'd simply like to use the chart here again — I did ask to have a
couple of things blown up, simply because I think it's a good illus-
tration—that even if you ignore the difficulties about melanoma in
terms of the lack of an exact cost-benefit, or cost risk to dose re-
sponse ratio, and simply focus on the non-melanoma sldn cancers
about which there is essentially 95 percent agreement among the
health scientists on this issue, the costs of the program, of the
phase-out program, are exceeded by the benefits by as much as 700
to one.
Now that's a cumulative number, admittedly, over the whole pe-
riod of the program.
So I would simply say that with respect to the accelerated phase-
out— that is, moving it from the year 2000 to the year 1996 — the
incremental cost of doing that was about $9.9 billion. That's mostly
in retrofitting things that would otherwise have been replaced. And
the benefits range there, again, just for the nonmelanoma cancers,
is approximately $220 to $860 billion.
I think, in the work that we do, that's an extremely attractive
investment.
I'd also like to just briefly focus on the major controversy, and
that is on the report by the CEI. And I know Mr. Lieberman is
here and he will adequately defend his own report. But I'd like to
just simply highlight why it is that we differ in our assessment of
the costs and benefits from the data that's put forward in that re-
port.
CEI claims that the phase-out will cost $45 to $100 billion. We
conclude that those numbers are way off. And they're way off be-
cause of a couple of key errors in the way that the assessment was
done.
Primarily, these have to do with some incorrect assumptions
about replacement schedules, an assumption that refrigerators
usmg HFC will cost $50 to $100 more, which is not true, an as-
sumption that the new technology is more prone to breakdowns,
which has not proven out to be true, failure to consider the im-
proved energy efficiency of the new refrigerators, which nets a ben-
efit of more than $5 billion over a ten-year period to the consumers.
As well as errors in the cost of retrofits and mistakes about the via-
bility of alternatives.
I think that I'll leave that up here and we'll, I'm sure, want to
refer to it later in questions and answers.
But I'd just like to conclude by saying that we at EPA are proud
of the work that we have been doing in implementing the Montreal
Protocol. We feel that it's a success story not only for the environ-
ment, but for the business community as well.
Thank you for your interest.
[The complete prepared statement of Ms. Nichols follows:!
192
TESTIMONY^F MARY D. NICHOLS
ASSISTANT ADMINISTRAJOR^R
A\RhiB-RAD\AT\OH
U.S. ENVIRONMENTAL PROTECTION AGENCY
BEFORE THE
SUBCOMMITTEE ON ENERGY AND ENVIRONMENT
OF THE
COMMITTEE ON SCIENCE
U.S. HOUSE OF REPRESENTATIVES
September 20, 1995
Mr. Chairman, Members of the Subcommittee, thank you for the opportunity to
testify before you on protection of the stratospheric ozone layer. The global phaseout of
CFCs and other ozone-depleting chemicals is an unparalleled triumph of the soundest
possible science, economics, and diplomacy. It rests on an ovenvhelming consensus
within the community of qualified sdentists. The same consensus exists among
qualified economists and business analysts on the costs and consequences of the
phaseout. The phaseout policy was developed under Presidents Reagan and Bush with
strong bipartisan support, and the Clinton Administration is proud to carry it footvard to
completion. This policy rightly enjoys overwhelming public support in this country and
around the worid. One hundred and fifty nations have become parties to the Montreal
Protocol, the treaty through which the phaseout is being accomplished woricf-wide.
Mr. Chairman, protecting the ozone layer should be a matter of common ground
between us. I am both puzzled and dismayed that, apparently, it is not.
I am especially dismayed by Congressman Delay's proposal to entirely repeal the
ozone layer protection provisions of the Clean Air Act, and by Congressman Doolittle's
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2
proposal - only one step less drastic - to rollback the CFC phaseout deadline to 2000.
These proposals would be disastrous to the ozone layer and to the health of the
American people. They would exalt fringe views on science and economics over the
intemational scientific consensus. They would wreak havoc in industries that have
invested very large sums of money, talent, and effort in carrying out the smooth
transition away from CFCs. Finally, they would put the United States in violation of the
Montreal Protocol and break faith with other nations that, under that treaty, have done
their part in the global effort to protect the ozone layer.
I have been asked to focus primarily on the scientific basis for accelerating the
CFC phaseout from 2000 to the beginning of 1996, and on the economic costs of doing
so. This decision was right when it was made under the Bush Administration in 1992,
and it is even more cleariy justified in retrospect today. Some of the witnesses here
today, who stand for outside the consensus of qualified experts, claim that the benefits
of this step were exaggerated and the costs underestimated. Building on the testimony
of Drs. Watson, Albritton, and Kripke, I will address why the critics are wrong on both
the science and the economics.
You will recall that the original Montreal Protocol was negotiated and signed in
1987 under PreskJent Reagan. President Bush was twk» responsible for accelerating
the phaseout of ozone-depleting substances, first in 1990 and again in 1992, to the
current end-of-year deadline for ending CFC production. The decision to speed up the
CFC phaseout to 1 996 was taken domestically under the Clean Air Act and
intemationally under the Montreal Protocol. As you are aware. Section 606(a) of the
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3
1990 Clean Air Act Amendments directed the Administrator to accelerate the phaseout
if any one of three conditions existed: .
• if at any time an assessment of current scientific information pointed to the
need for a more stringent schedule to protect the environment;
• if the availabifity of substitutes for listed substances made a more stringent
schedule practicable, taking into account technological achievability,
safety, and other relevant Actors; qt
• if the Montreal Protocol was modified to phase chemicals out more rapidly
than the then-existing Clean Air Act schedule.
All three of these conditions were met in 1 992, and remain valid today.
Addressing the first criterion, it is important to realize that the scientific basis for
accelerating the phaseout did not represent simply EPA's view of the science. From the
very beginning, EPA has relied on intemational scientific ozone assessments conducted
by several hundred of the world's leading atmospheric and health scientists, who
reviewed all available data. These assessments represent the definitive statement on
the state of the science and provide the soundest possible basis for EPA and
intemational action. The 1992 scientific assessment further strengthened the link
between CFCs and ozone depletion and showed that ozone depletion was taking place
at a substantially greater rate than had been thought just two years before, when the
deadline of 2000 was adopted. The most recent scientific assessment, issued eariier
this year (Scientific Assessment of Ozone Depletion: 1994; WMO Report 37), confirms
the conclusions of the 1 992 assessment concerning the effects of CFCs.
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4
You have heard various complaints about these assessments from witnesses
this morning. The substantive issues they raised were fully examined and thoroughly
rejected through the science assessment process. Basing policy on these scientific
assessments cleariy represents the use of sound science. To reject those assessments
based on the complaints you have heard today would mock sound science.
For example, the claim has been made that (1) UV-B radiation plays no rote in
the development of melanoma skin cancer and (2) therefore we need not be concerned
about ozone depletion. The first proposition is extreme: the preponderance of evkJence
suggests that UV-B does in ^ct play a significant role in causing melanoma, although
the exact dose-response relationship appears complex.
The second proposition is also misguided. The accelerated CFC phaseout would
still be easily justified even if there were ng link between UV-B and melanoma skin
cancers, because over 85% of the quantified health t>enefits of the phaseout come from
avoiding non-melanoma skin cancers and cataracts.
We have also heard it said that ozone depletion woukJ increase UV-B radiation
by no more than if you moved a few hundred miles south - whk^ people do all the time.
The reality is more serious. Cities near the equator receive about 20% more UV
radiation than cities further from the equator, and skin cancer rates in cities closer to the
equator are higher. For example, in a recent study, skin cancer rates for white males in
Albuquerque, New Mexico were approximately 700 per 100,000 versus 150 per 100,000
for a similar population in Seattle. Given current depletk>n rates of about 5% at
midlatitudes, people living in Washington, D.C. experience the equivalent of the
radiation they would have received if they visited Jacksonville, Florida. While it may not
■ ■ J ■
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5
matter if one person moves south, the reality of ozone depletion is a move south for the
entire U.S. population. The change in lifetime risk for the susceptible population for
developing skin cancer is significant.
We are cun^ntly experiencing depletion of approximately 5% at midlatitudes.
Moreover, if no action had been taken to limit CFCs, depletion would eventually have
reached as high as 20% or more, and UV-B increases and resulting increases in skin
cancers would have been drastic indeed.
Let me tum now to the second criterion set forth in the Clean Air Act: whether
the increased availability of substitutes for CFCs made it practical to speed up the
phaseout to 1996. Due to the maricet signals created by the phaseout, and to the
remari<able efforts of hundreds of finms in dozens of industries, the rate of technological
changes have exceeded all expectations. Once consensus existed on the need to
replace these substances, producers and manufacturers responded quickly and shifted
to alternatives. Because of these advances, no industry challenged moving the
deadline up to 1996.
As to the third statutory criterion, the Parties to the Montreal Protocol decided in
1992 to move the CFC phaseout up to 1996. Methyl chlorofomi and carbon
tetrachloride were also scheduled for phaseout by 1996, and halons were given a
deadline of 1994. The United States is one of 150 countries that is a Party to the
Protocol. We supported the 1996 deadline then, as did all our economic competitors. I
am not aware of any country in the worid that is considering any rollback on its CFC
phaseout commitment. In fact, much of Europe completed the phaseout last year. I
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6
should also note that any move to postpone the domestic phaseout deadline would put
this country in violation of the Montreal Protocol and intemational law.
I would now like to tum to the costs and benefits of our phaseout program.
Thorough cost and benefit analyses were undertaken both in 1990 for the decision to
phase out by 2000, and in 1992 to support the acceleration to 1996. These studies
reflect years of research on cause, effect, costs, and benefits. On the cost side, we
have extensively involved all aspects of industry - producers and users, big and small
companies, original equipment makers and service and repair industries.
Our studies and all inputs and comments from others were made public for
comment. We are confident that the numbers accurately reflect the costs and benefits
of this program.
Based on these extensive regulatory impact analyses, EPA's 1992 analysis
indicates that the benefits of the phaseout exceed its costs by a factor of up to 700 to 1 .
If we were to update this analysis based on the information available in the 1994
intemational assessments, this ratio of benefits to costs would continue to be
ovenwhelming. We estimated that the total cumulative cost of the current 1 996
phaseout requirements would be approximately $10 billion for the period 1989-2000,
and approximately $46 billion over the period 1989-2075, based on a 2% discount rate.
The total public health benefits from reduced cases of skin cancer, cataracts, and other
health effects are estimated to be between $8 and $32 trillion over the same period (the
range depends on the assumed value of a life). As noted above, 85% of the program's
benefits come from avoided non-melanoma skin cancers. The bottom line is that we
are getting an incredibly large bang for the buck!
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7
Despite these extensive analyses, some recent reports have outlandishly inflated
the costs of the phaseout. For example, the Competitiveness Enterprise Institute (CEI)
in its report, The High Cost of Coot," begins with demonstrably wrong Actual
assumptions, makes numerous methodological errors, and thus reaches unsupported
conclusions.
For exampile, the report erroneously implies that for many applications, existing
air-conditioning and refrigeration equipment will have to be discarded and replaced
immediately. This is just plain wrong. Existing equipment can remain in use indefinitely,
and substantial amounts of recycled CFCs will be available to repair that equipment for
years to come.
Further, industry has been extremely successful in developing low-cost retrofits
for existing equipment and highly energy-efficient new equipment that wori<s without
CFCs. Overall costs will be relatively low because these energy efficiency gains
significantly reduce lifetime operating expenses. In ^ct, in some sectors, such as
household refrigeration and building chillers, it will often pay for homeowners or building
owners to replace current equipment well before it has broken down.
Another emor the CEI report assumes that HFC-1 34a refrigerators will cost $50
to $100 higher than similar CFC-12 refrigerators. The leading refrigerator makers
disagree, however. According to them, the prices of these appliances will not increase
as a result of the altemative refrigerant. CEI's report also assumes that new technology
is more prone to ^ilure. But manufecturer warranties have not changed for the new
HFC-1 34a appliances. Again, CEI has feiled to consider that these new appliances are
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8
up to 30% more energy efficient, and will net consumers energy savings of $5.1 billion
over the next 10 years.
The CEI report also claims that the average cost of a mobile air-conditioner
retrofit is $433. In ^ct, the extra cost of a retrofit (over prior repair costs) was estimated
in 1991 to be $217. Because substantial progress continues to be made, the most
recent estimate is that a minimum cost retrofit (one that is made when other major
repairs are needed) will cost under $100. The marketplace has also responded to the
production phaseout by building significant reserves of CFC-12 for sale and use after
the production ban, which will permit millions of car owners to avoid retrofit entirely.
Additionally, a number of firms are developing and testing innovative refrigerants that
could even further reduce car owners' repair costs.
In sum, EPA estimates the cost of the phaseout to be $4 billion to the
refrigeration and air-conditioning sector over a 12-year period. While this is not an
inconsiderable sum, it is less than 1/10th to 1/25th of the inflated $45-100 billion figure
from CEI.
L^t me tum briefly to another ozone-depleting substance, methyl bromide, which
is scheduled to be phased out domestically under the Clean Air Act in 2001 . Methyl
bromide is a pesticide used in a substantial variety of agricultural applications. The
1992 and 1994 intemational scientific assessments have concluded that it is a powerful
ozone<lepleting chemical and an important contributor to ozone depletion, especially in
the near term. The 1994 UNEP Scientific Assessment of Ozone Depletion, peer-
reviewed by over 250 scientists, found that the ozone-depleting potential for methyl
bromide is 0.6. The range of uncertainty would bring it to no lower that 0.3 and no
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9
higher than 0.9. Even the lowest end of this range exceeds the 0.2 threshold that
makes a chemical a class I ozone depleting substance that must be phased out under
the Clean Air Act. The 1994 Science Assessment states that "Methyl bromide
continues to be viewed as a significant ozone-depleting compound." Additional
research is ongoing to address outstanding uncertainties, and to define the precise
OOP, which may turn out to be slightly higher or lower than 0.6. The Assessment also
stated that the elimination of anthropogenic methyl bromide emissions is the single most
effective policy to further reduce ozone destruction over the next several years.
Farm users of methyl bromide are understandably concemed that they do not
currently have satis^ctory substitutes for all uses of this chemical. I understand and am
sympathetic to their concern. In the long run, the critical issue, though, is not whether
technically and economically adequate alternatives for all methyl bromide uses are
available now, but whether they will be available by the time the phaseout deadline
arrives. There will not be a single chemical that replaces ail of the many uses of methyl
bromide. Alternatives to methyl bnsmide are often pest-specific, and can reduce pest
levels when used as part of an overall integrated pest management program.
Numerous chemical and non-chemical methods may effectively control many of the
pests on which methyl bromide is used. Research on additional altematives is under
way and will likely result in a wide range of options. Viable alternative materials need
not be identical to methyl bromide, but must effectively and economically manage pests
now being controlled by methyl bromide. , .
We fully recognize, however, that there is no guarantee that acceptable
altematives will be available for all uses of methyl bromide prior to 2001. We believe
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that having a safety valve - allowing continued production for specified essential uses
where no alternatives exist - is an important part of this process. To this end, we are
willing to work with stakeholders to craft an appropriate safety valve that would permit
applications for essential use exemptions if they are needed as the phaseout deadline
approaches.
The recent bill introduced by Congressman Miller is not an acceptable solution to
the problem. It would retum to the regulatory structure of the 1950's and 1960's by
overriding both the Clean Air Act and the Federal Insecticide, Fungicide and
Rodenticide Act and retuming effective control over this pesticide to USDA. The bill
would place the U.S. out of compliance vkrith the Montreal Protocol through which this
country has achieved unprecedented intemational cooperation to protect the ozone
layer under presidents of both parties. The bill would also replace the innovative,
market-driven phaseout process which has worthed flexibly and successfully for other
ozone-depleting chemicals with a complicated "command and control" regime requiring
specific rulings for thousands of current methyl bromide uses. By effectively blocking
the phaseout of methyl bromide in the U.S., the bill would ensure higher levels of
dangerous ozone depletion. We are willing to worit with stakeholders on an essential
use provision, as I have said. A broad rollback of the methyl bromide phaseout is
simply not waranted.
In closing, we must stay the course if we are to be successful in restoring the
ozone layer. We must continue our leadership role by meeting our phaseout
commitments as a Party to the Montreal Protocol, and ensuring that we take the
responsible road of decreasing skin cancer and cataract risks for our children and future
202
11
generations. This is where sound science and sound pdicy lead. I urge you to join and
support us in this effort.
Thanit you. Mr. Chairman, Members of the Subcommittee for your attention. I
would be happy to answer any questions you may have.
203
Mr. ROHRABACHER. Mr. Fay, we've got a vote that's coming up
in about 13 minutes. So you've got 5 minutes.
Then we'll break and we'll vote and we'll come right back.
STATEMENT OF KEVIN FAY, ALLIANCE FOR RESPONSIBLE
ATMOSPHERIC POLICY, ARLINGTON, VA
Mr. Fay. Thank you, Mr. Chairman.
You have my formal written testimony before you. I'll try to
quickly summarize our written statement.
At the outset, let me tell you that I represent the businesses and
industries, large and small, who have had to live with this issue
for the last 20 years. We're very interested in a good environment.
But we're also very interested in a good economic climate in
which to do business. We're interested in balanced budgets, regu-
latory reform, low taxes, and other such desirable things.
But there are so many myths and misrepresentations on this
issue, it's difficult for policy-makers and for businessmen often-
times to know which way to turn.
Let me make one thing real clear.
No one, no one, not us, not the environmentalists, not EPA, not
the scientific community, not the media, and not political policy-
makers, can claim the mantle of complete virtue on this issue.
First of all, I can state without any doubt, as one who has lived
throughout this entire 20-year process on this, the acceleration of
the phase-out of CFCs in 1992, had nothing to do with the Feb-
ruary, 1992 press conference by NASA.
The decades-long examination of ozone science is well understood
and supported by expert industry scientists.
From our perspective, while we may disagree on the rates of
chsinge or estimates of environmental effects, we long ago reached
an agreement on the appropriate course of action.
There's no question that political opportunists have taken their
shots at us and at the American consumers through the adoption
of multi-billion-dollar excise taxes or through the adoption of cer-
tain unnecessary regulations mandated by the Clean Air Act.
Political opportunists continue to try to take advantage of this
issue. Recent efforts to try to portray the so-called analysis as fact,
such as CEI has done, or to somehow link the deaths, as he tried
to do recently in his op-ed piece, the deaths in the Chicago
heatwave, is shocking in its irresponsibility.
Even Fred Singer this morning agreed that CFCs should be
phased out.
What we are debating is the rate of change both in the environ-
ment, in the industry, and among the public.
The crux of the policy debate appears here to be over about four
to five years of CFC production.
The realities are the fundamental scientific basis for the CFC
phase-out is credible and has remained basically unchanged since
the original policy decision to phase out production of the com-
pounds.
The producer and user industries acted responsibly in moving
quickly to develop and implement safe and effective substitute
technologies that allowed that phase-out to be accelerated.
204
Because of that quick action, further harsh measures regarding
other compounds such as HCFCs, are unnecessary today.
Much work remains to be done, however, in order to ensure full
compliance with the protocol both here and at the international
level, including completion of the phase-out in developing countries.
Much still can be done to reduce the costs and regulatory bur-
dens imposed as a result of the congressionally mandated excise
taxes and certain provisions of the Clean Air Act.
While we think the examination of the scientific activities is cer-
tainly useful, we believe that the proper congressional focus at this
time should be the streamlining of policies in effect in this country
and at the international bargaining table.
This should be done in order to ensure the completion of the
transition out of ozone-depleting CFCs while maintaining our eco-
nomic competitiveness.
We have several suggestions.
At the international level, the U.S. should take a strong position
that there's no need to alter the protocol's control schedule on
HCFCs. The protocol's technology and assessment panel experts, of
which we have participated, have agreed that HCFCs are critical
in order to achieve the CFC phase-out.
The protocol parties must continue progress to have the develop-
ing countries eliminate their reliance on CFCs. The treaty does
provide for a delay of phase-out in these countries.
Many major developing countries, including Brazil, China, Mex-
ico and Malaysia, have announced phase-outs well in advance of
the treaty requirements.
The U.S. should be fostering these actions by fulfilling its exist-
ing financial commitment to the protocol multilateral fund, rather
than eliminating funding, as has been proposed in the current ap-
propriations process.
According to one estimate, the government has collected more
than $6 billion in ozone depletion excise taxes from U.S. consumers
of CFCs. It is difficult to understand the justification for not fund-
ing the protocol efforts since the American taxpayer has paid for
it.
The more quickly developing countries phase out of CFCs, the
more likely that U.S. technologies, with their accompanying jobs,
could be adopted in order to accomplish this objective.
Because of the quick action to address the issue internationally,
the parties to the protocol should also be encouraged not to revisit
the treaty every two years in anticipation of major amendments.
This is what they've been doing.
The basic framework is working well and should not now be re-
visited unless there is significant new scientific information.
At home, several steps could be taken in order to streamline the
regulatory provisions.
The Congress could eliminate several provisions of Title 6 of the
Clean Air Act amendments that have the potential to impose great
costs, but which provide no significant environmental benefit.
The labelling provisions, particularly with regard to HCFCs,
should be deleted altogether.
The safe alternatives program could be sunset once there is no
nexus to substitution of ozone-depleting compounds. In fact, the al-
205
liance has filed a legal challenge to the EPA snap program in order
to prevent unnecessary overreaching. And provisions eliminating
the use of substitutes in so-called non-essential products could be
deleted.
Continued increases in the ozone depletion excise tax, which is
scheduled to continue going up every year, should be ended. In fact,
if the Congress is truly concerned about the cost to the consumer
of the ozone protection program, it could adopt a tax credit for
equipment retrofits.
The alliance believes that such a program could be revenue-neu-
tral in the near- term.
Finally, the government must continue to enforce the laws con-
cerning the illegal import of CFCs. The illegal imports and the
avoidance of excise tax in these compounds m^e CFCs more avail-
able, reduce the incentive for users to shift, and penalize legitimate
companies who are complying with the laws.
The illegal imports create the impression in the marketplace that
CFCs are plentiful and that retrofits can be deferred.
They're also frustrating the attempts of legitimate businesses to
plan for the post-production period.
Finally, the effects science should be continued. We do not have
a good scientific understanding of ozone depletion effects. There is
no question about that. We've known that all along. It's shocking
that it has not been done.
I will stop there and let you go vote.
Thank you.
[The complete prepared statement of Mr. Fay follows:]
206
Alliance for Responsible Atmospheric Policy
2111 Wilson Boulevard
Arlington, Virginia 22201
703-243-0344
Fax 703-243-2874
TBSTrMON\^OF
KEVIN Fi^
ALLUNCE FOR RfiSPeNSfBirEATMOSPHERIC POLICY
HOUSE COMMITTEE ON SCIENCE
SUBCOMMITTEE ON ENERGY AND ENVIRONMENT
SEPTEMBER 20, 1995
Thank you Mr. Chairman, and members of the Committee. My name is Kevin Fay; and I
am counsel to the Alliance for Responsible Atmospheric Policy. I am pleased to appear
before you on behalf of the approximately 250 industry members of the Alliance. The
Alliance is a U.S. industry coalition that was organized in 1980 to address the issue of
stratospheric ozone depletion and efforts at that time by the United States government to
unilaterally further regulate the production and use of chlorofluorocarbons, or CFCs.
Today, the Alliance coordinates industry participation in the development of reasonable
international and U.S. government policies regarding ozone protection.
We are particularly pleased to have the opportunity to address the topic before the
committee today: "Stratospheric Ozone: Myths and Realities". Over the last two
decades, it appears that the ozone protection issue has generated enough myths and
discussion to fill several books. It has become difficult to separate these myths from
reality.
E>epending on the "politically correct" vantage point, the ozone depletion story is either
about industry and technology bringing about global destruction in pursuit of fmancial
gain; or in the alternative, environmentalism and social engineering out of control. From
our perspective, the ozone depletion issue is about complex scientific information
concerning the impacts of technology on the environment, and efforts to lessen these
impacts in as cost-effective manner as possible.
The realities are:
--that the fundamental scientific basis for the CFC phaseout is credible,
and has remained basically unchanged since the original policy decision to phase out
production of the compounds;
207
"that the producer and user industries acted responsibly in nwving quickly
to develop and implement safe and effective substitute technologies that allowed the
phaseout to be accelerated;
—that because of quick action by industry, further harsh measures
regarding other compounds such as HCFCs are unnecessary;
-that much work remains to done in order to ensure full compliance with
the Protocol at the international level, including completion of the phaseout in developing
countries and better enforcement of trade in illegally imported material; and
-that much can be done to reduce costs and regulatory burdens imposed as
a result of Congressional mandated excise taxes and certain provisions of the Clean Air
Act
A brief review of ozone protection history would be helpful at this point.
When the Alliance was organized in 1980, the ozone depletion theory was six years old.
However, a panel of industry scientific experts, the Fluorocarbon Program Panel of the
Chemical Manufacturers Association, had been meeting since 1972 to consider the
question of what happens to CFCs in the atmosphere.
CFCs and CFC-reliant technologies developed over the last several decades contributed
substantially to the quality of life for our society. In 1980 we believed that rigorous
scientific analysis would eventually disprove what was then considered to be an unproved
scientific theory.
When it was organized, the Alliance's goals were to ensure that any regulatory decisions
be based on the best scientific information available; that any proposals for action be
pursued at the international level, particularly in light of the global nature of the issue and
the tremendous competitiveness concerns for the industries that could be affected; and
that any proposals not single out specific industries for regulatory scrutiny (as had been
done in the late 1970's with the U.S. aerosol ban.) We have achieved these goals because
sound science has resulted in internationally agreed upon controls which are responsible
and cognizant of societal needs in specific sectors.
208
In 1986, the comprehensive assessment of ozone science was released by NASA and the
World Meteorological Organization (WMO). It was on the basis of the information
contained in that assessment, information that industry experts had assisted in developing,
that industry representatives came to the conclusion that the potential existed for serious
and unacceptable future environmental risks, if CFC growth continued well into the next
century. It was an appropriate and responsible result.
On September 16, 1986, the Alliance publicly released a statement which acknowledged
this information, and issued the first call by industry for the negotiation of an agreement
at the international level to limit the production of these compounds. (Attachment 1).
The Montreal Protocol was completed and signed exactly one year later. The original
treaty then called for only a 50% reduction in the production of CFCs and a freeze in
halons by 1998.
The treaty was the first signal to the marketplace to accelerate development of CFC
substitutes. The view at the time by many in industry was that CFCs could still be used,
but that stopping growth in their use would be difficult. The "race was on", however, to
develop and implement safe and effective alternatives if companies were going to
compete with technologies that were to be economically viable.
The scientific developments after completion of the Protocol focused both on the 1986
discovery of the Antarctic ozone hole and continued refinements of the atmospheric
models based on better observational data from the atmosphere and the laboratory.
Again, industry scientists were familiar with this work and integral to its completion.
Scientific consensus developed around several key elements;
—atmospheric chlorine concentrations appeared consistent with emissions of CFC
compounds since their production began in the 1930's;
--the Antarctic ozone hole appeared to develop when stratospheric chlorine
concentrations reached 2 parts per billion;
—the ozone hole appeared to result from a complex series of chemical reactions
and the unique Antarctic meteorology which triggered the availability of free chlorine
radicals in the atmosphere when the first sunlight of springtime appeared. The primary
source of the chlorine came from chlorine- and bromine-containing compounds; and
209
-continued use and emissions of chlorinated and brominated compounds,
including CFCs were projected to result in a substantial increase in atmospheric chlorine
and bromine over the next several decades, even with the Montreal Protocol reductions.
The NASA/WMO Ozone Trends Panel Executive Summary of March 15, 1988 led
policymakers to conclude that production of CFC compounds needed to be eliminated
altogether. The scientific information led to the 1990 amendments to the Protocol to
phase out these compounds by the year 2000. Efforts to identify CFC substitutes were
accelerated even further.
E)omestic events had also focused additional attention on the issue, with the adoption by
Congress over industry objection, of the excise tax on ozone depleting compounds in
1989; and with the completion of the 1990 Clean Air Act Amendments. The tax, which
rose from $1.25 per pound of CFCs to $5.35 this year is a severe penalty on consumers.
The message to the industry was clear - these compounds were going to be taxed, reduced
and ultimately phased out. It was clearly in industry's interest to do everything possible
to introduce substitute technologies as rapidly as possible. The industry's goal was to
manage the transition away from ozone depleting chemicals, while preserving the
benefits their technologies provided along with the desirable health and safety
characteristics that these technologies provide.
A multi-billion dollar investment in new technologies was needed to shift manufacturing
techniques and introduce new products relying on new compounds such as
hydrofluorocarbons (HFCs), hydrochlorofluorocarbons (HCFCs), and other chemical or
not-in-kind technologies.
At the same time, the Alliance continued to call to policymakers' attention the problem of
dealing with the existing base of CFC-reiiant installed equipment, particularly air
conditioning and refrigeration equipment, which has been estimated to be worth more
than $135 billion. This issue was paramount when the Alliance was founded in 1980, as
well as in 1986 when we called for international action. Our grounds for opposition to
the excise tax was that it is unfair to tax consumers who had no other recourse but to pay
the tax in order to have their motor vehicles and equipment serviced. It was primary in
our request during the Clean Air Act Amendment debate for an exemption from the
production phaseout for the service of this equipment.
210
In 1991-92, in the face of the continuing drumbeat of additional scientific reports of the
worsening atmospheric conditions, policymakers were moving once again to accelerate
the reduction schedule. Technology assessments completed internationally and here in
the United States concluded that technologies would soon be available to eliminate the
need for CFC compounds in most manufacturing applications.
The transition fix)m CFCs was slowed due to the uncertainty over policies which might
have been adopted concerning the HCFC substitutes. The HCFCs were deemed essential
by the Protocol experts in order to achieve a CFC phaseout. Some European countries
had already proposed eliminating HCFCs by the year 2000. The transition was also
slowed by delays in implementing certain provisions of Title VI of the Qean Air Act
Amendments, particularly Section 612 dealing with the approval of "safe alternatives"
(known as the SNAP Program). Also of great concern was the implementation of other
Title VI provisions, particularly labeling, which had the potential to impose substantial
costs on products that ultimately would have been borne by consumers, and the continued
problem that no policymaker seemed willing to address: the problem of the existing
equipment base.
The existing equipment issue was particularly vexing because neither the Clean Air Act
Amendments nor the Montreal Protocol contained any provision or procedure for
assuring the continued viability of this equipment. To our knowledge, no environmental
program has ever before or since required the kind of massive scale retrofit of millions of
commercial and consumer products. Industry needed a strategy to deal with this concern.
As a result, the Alliance filed a petition with the Environmental Protection Agency (EPA)
on February 11, 1992 to accelerate the phaseout of CTFCs consistent with anticipated
^availability of technology implementing CFC substitutes. (Alliance press releases and a
summaiy of the petition are enclosed as Attachment 2). In retiun, the Alliance requested
the government to provide a reasonable period of assured usage for the HCFC
technologies; defer the majority of the labeling requirements; provide a policy framework
for assuring production of CFCs for the existing equipment base; and accelerate the
determinations of safe alternatives under section 612 of the Clean Air Act Amendments.
As a result of this petition and other efforts, the CFC phaseout was accelerated to January
1, 1996 as part of the 1992 Copenhagen amendments to the Montreal Protocol. More
importantly, the industry received approvals of its alternatives under the SNAP program;
the domestic labeling provisions were essentially delayed; the parties to the Protocol
5
211
adopted a schedule allowing use of the HCFCs until 2030; and the Protocol was amended
to put in place a process for seeking an essential use exeinption for continued CFC
production.
An important lesson was learned during this period and the HCFC use strategy that was
adopted actually incorporates a "service tail" as part of the production schedule so that the
existing equipment problem being experienced on CFCs would be much reduced with
respect to HCFCs.
The United States is currently in its last year of CFC production for domestic use under
the Protocol and Clean Air Act requirements. Use of these compounds during the last
five years has consistently been less than that allowed by the treaty. The reductions are
due to several factors, including:
—more rapid replacement of CFCs with substitute compounds or not-in-
kind technologies than was previously anticipated;
—greater efforts to reduce servicing losses as a result of the high cost of the
CFC refrigerant and the implementation of now mandatory rules prohibiting the venting
of refrigerants;
—more careful management of the use of the compounds in all sectors,
including electronic solvent cleaning, medical uses, high efficiency insulating foams, etc.;
and
—a black market for CFCs.
Despite these lower than projected use levels, concern remained high for the existing
equipment base. As a result, manufacturers, distributors, wholesalers, building owners,
and refrigeration service networks, have adopted their own strategies for assuring the
needed supply of the compounds in the post- 1995 CFC-phaseout period. These strategies
have required the investment of millions of dollars in CFC banks, assistance programs for
customers concerning retrofit decisions, as well as efforts with large customers to bank
their own multi-year supply of refrigerants for this equipment.
There is no easy or uniform solution to this issue. The charges made by some, however,
that the "impact on consumers was scarcely considered," is not accurate. The fact is that
212
industry actions have been guided by unprecedented concern by the affected industries
for the costs on their customers, and on the health, safety and welfare of the users of the
existing and substitute technologies. It is possible that problems in performance or other
parameters will arise with the substitutes. That is the inevitable risk of an accelerated
phaseout. Industry has done its best to avoid such problems.
Management of the ozone depletion issue continues to be an unprecedented effort on the
part of industry, government, and yes, responsible environmental group representatives to
address a unique global concern. We have expended more than $6 billion to implement
these new technologies on a world wide basis.
As we stated at the outset, the myths of ozone depletion do not stand up to credible
scrutiny. The reality is that the Montreal Protocol process has worked much better than
anyone has anticipated. The focus is not on whether the science justified the actions that
were taken. There was enough scientific consensus on which to make credible policy
decisions. Industry has participated in that process and, to the best of our ability,
provided guidance on the means to accomplish the environmental protection agenda in as
cost-effective a manner as possible.
The Alliance believes that the proper Congressional focus should be the streamlining of
policies in effect in this country and at the international bargaining table. This should be
done in order to ensure the successful completion of the transition out of ozone-depleting
CFCs, while maintaining our economic competitiveness. We have several suggestions.
At the international level, the United States should take a strong position that there is no
need to alter the Protocol's control schedule on HCFCs. The Protocol's technology and
assessment panel experts have agreed that HCFCs remain critical to the elimination of
CFCs, and further tightening of controls on these compounds provide little or no benefit,
particularly if such actions were to encourage continued developing country usage of
CFCs. Concern for growth and continued production of CFCs in developing countries
should be a priority since such activity could severely slow recovery of the ozone layer.
The Protocol parties must continue progress to have developing countries eliminate their
reliance on CFCs. The treaty provides for a delayed phaseout of CFCs in these countries.
Many major developing countries, including Brazil, China, Mexico, and Malaysia, have
announced phaseouts well in advance of the treaty requirements. The U.S. should be
fostering these actions by fulfilling its existing financial commitment to the Montreal
7
213
Protocol Multilateral Fund, rather than eliminating funding as has been proposed in the
current appropriations process. (According to one estimate, the government has collected
more than $6 billion in ozone depletion excise taxes from U.S. consumers of CFCs. It is
difficult to understand the justification for not funding the Protocol efforts since the
American people are paying for it through this tax.)
The more quickly developing countries phase out of CFCs, the more likely that U.S.
technologies, with their accompanying jobs, could be adopted in order to accomplish this
objective.
Because of the quick action to address the issue internationally, the Parties to the Protocol
should also be encouraged not to revisit the treaty every two years in anticipation of
major amendments. The basic framework is working well and should now be revisited
only upon significant new scientific information.
At home, several steps could be taken in order to streamline regulatory provisions. The
Congress could eliminate several provisions of Title VI of the Clean Air Act
Amendments that have the potential to impose great costs, or subject specific industries,
small businesses, and consumers to potential liability for no significant environmental
gain. The labeling provisions, particularly with regard to HCFCs should be deleted
altogether, the SNAP program should be sunset once there is no nexus to substitution of
ozone depleting compounds (the Alliance has filed a legal challenge to the SNAP
program in order to prevent unnecessary overreaching on the part of EPA); and
provisions eliminating the use of substitutes in so-called "non-essential products" could
be deleted. Decisions by government are not as efficient as the marketplace.
Continued increases in the ozone depletion excise tax should be ended. In fact, if the
Congress is truly concerned about the costs to the consumer of the ozone protection
program it could adopt a tax credit for equipment retrofits. The Alliance believes that
such a program would be revenue neutral in the near-term.
Finally, the government must continue to enforce the laws concaming the illegal import
of CFCs. Illegal imports and the avoidance of excise tax on these compounds make
CFCs more available, reduce the incentive for users to shift to alternatives, and penalize
legitimate companies who are complying with U.S. laws. The illegal imports create the
impression in the marketplace that CFCs are plentiful, and that retrofits can be deferred.
8
214
The illegal imports are frustrating the attempts of legitimate businesses to plan for the
post-production period through stockpiling.
Just because the Montreal Protocol has worked well does not mean, as some would have
it, that all future global environmental initiatives would be patterned after the Protocol's
ban on specific chemicals, or that it means the creation of some supranational regulatory
body. The Protocol was designed to address a unique set of scientific, economic, and
environmental circumstances that was not well understood by the public, the media, or for
that matter, many policymakers. It is difficult to envision a similar set of circumstances
on other more typical environmental issues. It is encouraging to note that when the
circumstances warranted such action, that governments and industries alike were able to
put aside more parochial concerns and act in the interest of the general public good.
Because of industry's active role in understanding the science, and assessing the economic
and policy issues, we believe that the process has gone better than it could have. The
costs involved are real. While the benefits are still being assessed, we stand by our record
of rapid response and participation in this process. We encourage the Congress to further
enhance this process by using hearings such as these to better understand the issues, and
to streamline the regulatory procedures and the burdens they entail, but to also remain
tnindful of the historical perspective involved with the establishment of the original
policy objectives within which we have had to operate.
215
ATTAOHMBMT I
STATEMENT
OF
RICHARD BARNETT
CHAIRMAN
ALLIANCE FOR RESPONSIBLE CFC POLICY
September 16, 1986
National Press Club
Washington. D.C
Good Morning Ladies and Gentlemea*
I have a brief statement that I will read after which I will be happy to answer your questions.
The Alliance for Responsible CFC Policy was organized six years ago to represent the interests of users and pro-
ducers of chlorofluorcartwns (CFCs). This was in response to what we considered to be an unwarranted proposal by
the U.S. Environmental Protection Agency ( EPA) to cap and eventually reduce production of this unique family of
chemicals which have contributed so significantly to the quality of life of all Americans and to people around the
world. The proposed EPA action was based on the theory that CFCs are emitted into the atmosphere uid, because
of their unique stability, eventually reach the earth's protective ozone layer, where they may deplete the ozone
through a complex series of reactions.
In the belief that government ought not regulate based on an improven or unverified theory. Alliance members
established some basic goals with regard to the ozone depletion theory, CFC usage, and potential government
policies.
First, it was our desire to encourage the pursuit of adequate credible scientific research on this important environ-
mental issue, and then to ensure that any government policy be based on the best and most current scientific
information:
Second, it was our goal to encourage efforts to resolve this issue in the international arena because of its global
scope and to prevent any unproductive, harmful, unwarranted unilateral domestic regulatory program that would
injure U.S. industry to the benefit of our international competition;
Third, it was our goal to amend the Clean Air Act to provide greater international emphasis on this issue and to
give better guidance to the EPA Administrator regarding stratospheric ozone protection activities and the need
for regulation.
In the six years that have gone by, we feel that much has been accomplished to obtain our goals, but we believe
that much remains to be done.
We have seen wide swings of Tindings from conflicting scientific reports regarding CFCs and ozone depletioa
With as much as we have learned from the intensive scientific scrutiny, we have also learned that there is a lot we still
do not know. We beUrve the scientific research must continue.
In the intervening years, the Alliance has informed our political leaders, administrative oGFicials, and the publio-
at-large, as to the many benefits that CFCs offer to our society, in comfort control, food preservation and prepara-
tion, energy efficiency, cleaning and sterilization processes, and many other uses, as well as the tremendous
contribution to worker and consumer health and safety.
Additionally, we have been an active participant in efforts to promote greater international cooperation, as exem-
plified by our support for the Vienna Convention for Protection of the Ozone Layer, and our participation in domes-
tic and international efforts to address ozone protection issues such as the recently concluded series of workshops
sponsored by EPA and the United Nations Environment Programme.
As you can imagine, the Alliance's activities as a coaUtion require the active physical as well as financial par-
ticipation of our member companies. We have worked to live up to our name and be an Alliance for Responsible
CFC Policy. To do so requires a constant evaluation of the complex scientific economic and environmental policy
issues confronting us and maintaining and, if necessary, adjusting our position in accordance with the most current
information available to us.
In 1 980, the Alliance urged that at least 3 to S years was necessary to allow the scientific research to continue and
to gather critical monitoring information regarding the projections being made by computer models. Therefore, the
1 986 release oftheNASA/WMO science assessment on stratospheric ozone was an important event with regard to
our own continuing evaluadon process.
In general, I want to stress that the Alliance does not believe that the scientific information demonstrates any
aetoal risk from current CFC use or emissions. We recognize, however, the growing concern for potential ozone
depletion and climate change as a resuh of large future growth of CFC emissions and the buildup of many other trace
gases in the atmosphere, and the concern with the discovery of imexplained phenomena such as the large reductions
in ozone levels during the Antarctic spring.
M
216
The science is not sufficiently developed to tell us that there is no risk in the future. In fact, all of the computer
models calculate that large future growth in CFC emissions may contribute to significant ozone depletion in the lat-
ter half of the next century.
We support fiuiher scientific research and believe that regulatory policies should be periodically reexamined in
the light of additional research fmdings.
On the basis of current information, we believe that large future increases in fully halogenated CFCs (the most
durable ones, thought to contribute most to ozone depletion) would be unacceptable to future generations and, in our
view, it would be inconsistent with the goals of this Alliance to ignore the potential for risk to those future
generations.
The Alliance, therefore, believes that a responsible policy is necessary that meets four criteria. The policy
must
—provide some assurance that we never reach the "doomsday" scenarios that have been put forth;
—foster the spirit of international cooperation needed to reach scientific consensus on this issue and the need for
an appropriate global response;
-fulfill our responsibilities as businessmen and women to our shareholders, employees, and customen;
and
—recognize the substantial contributions that CFCs make to the quality of our lives, and to the health, safety,
and economic benefit of workers and consumers alike.
I am pleased to announce to you today, that the Alliance Board of Directors approved the following policy state-
ment on September 4th. We believe this policy statement meets the criteria I have just stated
Further, we believe that this policy is a significant step in the direction of developing a positive approach to the
issue of global ozone protection and the responsible use of CFCs. We recognize that the process of developing these
prudent precautionary measures and establishing specifics will not be easy. As a coalition of many companies and
industries, we may expect more specific policy suggestions from our members. We look forward to contributing to
the development of the broader consensus on this issue, and hope that others will join us in a spirit of international
cooperation as we pursue the difficult tasks necessary to achieve a global policy consensus in the months and
years ahead.
Thank you.
1-2
217
ATTACHMBHT 2
ALLIANCE FOR RESPONSIBLE CFC POLICY
1901 NORTH FORT MYER DRIVE. SUITE 1200
ARLINGTON. VIRGINIA 22209
(703) 243-0344
FAX (703) 243-2874
For Immediate Release For Information Contact:
Kevin Fay 703-243.0344
ALLIANCE PETITION SEEKS MORE THAN 50% REDUCTION IN
OZONE DEPLETION COMPOUND ALLOWANCES
Washington D.C., February 11, 1992 - The Alliance for Responsible CFC Policy,
an industry coalition composed of CFC and HCFC producers and users, today petitioned
U.S. Environmental Protection Agency (EPA) Administrator William Reilly to accelerate
the phaseout schedule for CFCs and certain atmospheric long-lived HCFCs.
Alliance Executive Director Kevin Fay stated, 'The accelerated schedule we have requested
EPA to implement domestically and internationally for phasing out these ozone-depleting
compounds is more than a 50% reduction from that which is currently allowed by the
Montreal Protocol. It is consistent with technological and economic feasibility, the health
and safety concerns of workers and consumers, and environmental protection needs. It
represents a difficult but realistic schedule for the phaseout of these compounds. "
The Alliance petition was filed in acknowledgment of substantial technological advances as
well as in response to announcements over the last year concerning additional
measurements of potential ozone depletion around the globe. The significant proposed
reduction schedule is possible, according to the Alliance, because of progress made by
industry in developing ozone protective CFC replacement technologies. These
technologies are identified in the December 1991 United Nations Environment Programme
(UNEP) Technology and Economic Assessment Report
The Alliance petition requests that the ban on the production and use of CFCs for new
equipment take place on January 1, 1996. Presently, both the Montreal Protocol and the
Clean Air Act require that production of CFCs be ended by January 1, 2000, although it is
likely that the Protocol will be revised later this year.
The Alliance also believes that the present CFC phasedown schedule can be accelerated at a
rate which is achievable in light of industry's technological capabilities. Therefore, the
following production schedule has been requested in tcxlay's petition:
Percentage Production of 1986 Baseline Levels
Year
Montreal Proiwol
Clciwi Air Act
Alliance Petition
1993
too
75
50
1994
100
65
40
1995
50
50
25
1996
50
40
0*
1997-1999
15
15
0*
2000
0
0
0*
*exemptionfor service of equipment, to he determined in future technical assessments.
218
"While industry has made substantial progress in reducing CFC production and usage,
encouraging recovery and recycling of the compounds, and making a safe transition to
alternative compounds significant hiffdles still remain. The petition takes into consideration
the time it will take for EPA to determine whether the alternatives are acceptable for a period
of time to justify their production. It also represents a very demanding schedule upon
which industry can complete its implementation of the alternatives in the products and
processes that use them," Fay said.
The petition also recognizes the needs of consumers and businesses who own over $135
billion of existing equipment such as automobile air conditioners, refrigerators, and large
air conditioning systems which operate on CFCs. While some have advocated that the total
CFC production phascout occur between 1995 and 1997, the Alliance requests that from
January 1, 1996 until January 1, 2000, a limited amount of production be allowed annually
to service and maintain existing refrigeration and air conditioning equipment This amount
is to be determined by future technology assessments on the availability of cost-effective
retrofit technology and the success of CFC recycling and reclamation efforts.
Any anempt to eliminate CFC production without consideration of the existing equipment
would create a potential shortfall of necessary refrigerant to service this equipment Such a
shortfall would result in the early obsolescence of this equipment, and reduced operating
efficiencies which could cause increased energy consumption by this equipment. While
CFC recovery and recycling will make up for some of the shortfall, no study has indicated
that a shonage can be eliminated through even the most aggressive recycling and
conservation efforts.
The petition also requests acceleration of the phaseout schedule for HCFC-22, HCFC-
141b, and HCFC-142b beyond the current Clean Air Act requirements. Under the Alliance
petition, production of these compounds for use in new products or equipment would be
ended by January 1, 2010. Total production of these HCFCs would be ended by January
1. 2020.
The Alliance For Responsible CFC Policy, organized in 1980, is a coalition of U.S.
companies that produce CFCs, HCFCs, and HFCs, as well as products and processes that
rely on these compounds. CFCs and HCFCs are used extensively as refrigerants in air
conditioning and refrigeration equipment, including motor vehicles; as solvents in the
electronics industry; as blowing agents for the manufacture of high efficiency foam
insulation and foam packaging; and as sterilants and medical aerosols in the health industry.
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219
Table 1
ACTIOMS REQUESTED BY ALLIANCE PETITION
Accslerated Phaseout of CFCs:
Allowable Annual Production
Year of 1986 Quantities
1993 50%
1994 40%
1995 25%
1996 0% for new equipment
1996-1999 Allocation for service of
equipment manufactured
before Jan. 1, 1996
(amount to be determined)
2000 0%
No production of CFCs after January 1, 1996 for use in
equipment manufactured after that date.
A production allowance from 1996-1999 (amount to be
determined based on 1986 levels) for service of
refrigeration and air-conditioning equipment
manufactured before Jan. 1, 1996.
Accelerated phaseout of HCFC-22, HCFC-141b and HCFC-
142b:
After Jan. l, 2010 No such HCFCs allowed to
be produced for use, or
used, in new products and
equipment.
After Jan. 1, 2020 No production allowed.
Limited one-year waiver from accelerated CFC phaseout
for applications where no substitutes are viable
Minimum period of 15 years for safe alternatives
Deferral of labeling except for containers or products
containing CFCs until Jan. l, 1995
Exemptions for products demonstrated as essential under
Section 610(d) (2)
Coordination of U.S. actions with Montreal Protocol
negotiations
220
ALLIANCE FOR RESPONSIBLE CFC POLICY
1901 NORTH FORT MYER DRIVE. SUITE 1200
ARLINGTON. VIRGINIA 22209
(703) 243-0344
FAX (703) 243-2874
For Immediate Release For Information Contao:
Kevin Fay 703-243-0344
ALLIANCE PLEDGES SUPPORT FOR PRESIDENT'S PROGRAM ON
OZONE LAYER, PETITIONS EPA FOR PROMPT ACTION
WASHINGTON, D.C., February 11, 1992 - The Alliance for Responsible CFC
Policy, an industry coalition composed of CFC and HCFC users and producers, endorsed
the call today by President Bush to accelerate the domestic and international efforts to
protect the eanh's ozone layer, and filed a petition with EPA requesting acceleration of the
phaseout schedule for cenain ozone depleting compounds. "The United States, both
government and industry, will maintain its leadership position in the global ozone
protection effort," said Kevin Fay, the Alliance Executive Director. "The President's action
today is responsive to the environmental concerns announced last week by NASA, and
consistent with the technological advances achieved by industry in developing substitute
chemicals and technologies. '
The CFC Alliance has urged that the critical steps necessary to accelerate the
phaseout of CFC compounds are:
-the rapid approval by EPA of industry developed substitutes as required
by the Clean Air act;
"development of an action plan to deal with the huge base of existing
installed equipment, primarily refrigeration and air condinoning equipment;
"invigorated diplomatic efforts to ensure the participation of all nations,
particularly the developing nations, in the Montreal Protocol process; and
-swift action by the Federal government to implement procurement policies
for ozone protecting technologies, as well as recycling, reclamation, and
retrofit programs for government owned existing equipment.
"The President's proposal addresses several of these key elements. U.S. industry
will actively assist the Bush Administration in the prompt implementation of these steps,"
said Fay. "The Montreal Protocol has achieved an unprecedented level of cooperation in
addressing this serious global environmental concem. Without the technical, financial, and
political support of the U.S. government, as well as industry, the world would be unable to
deal with this environmental crisis. U.S. industry pledged its support in 1986 to address
this issue in a responsible manner. Our support for the President's action today is
consistent with that commitment."
"The use of market mechanisms to implement the Montreal Protocol have been
largely responsible for the industry's ability to reduce its reliance on CFCs well-ahead of
current regulatory mandates, " said Fay. According to EPA figures, the U.S. has already
reduced its reliance on CFCs 40% greater than that required by the Protocol.
221
In response to the President's call to U.S. CFC producers to immediately reduce
CFC production to 50% of 1986 baseline levels. Fay indicated that he believed that the
U.S. producers, Allied-Signal, DuPont, Elf Atochem. and LaRoche, would respond
affirmatively.
At the same time, the Alliance pointed out that the President's plan achieves the
environmental objective while recognizing the needs of American consumers and small
business. In 1996, the United States will have 130 million automobiles, 160 million
refrigerators and freezers, 5 million commercial refrigeration and air conditioning systems,
and 80,000 large building chillers that run on CFCs. This equipment, valued at more than
$135 billion, will require a mix of recycled CFCs, a limited amount of new CFC
production, and the application of cost-effective retrofit technologies in order to avoid huge
capital obsolescence costs to the economy.
The Alliance reponed that it filed a petition with EPA today to accelerate the CFC
reduction schedule, achieving a phaseout of production by December 31, 1995. The
petition also seeks a limited exemption from the phaseout in order to service the existing
equipment base. The exception would only be utilized if subsequent technical
developments do not produce cost-effective solutions for retrofitting this equipment and
reclaimed and recycled refrigerant is unable to provide for its needs. The petition is
consistent with the President's action.
The petition also seeks an accelerated phaseout of the atmospheric long-lived
HCFCs, bridging compounds needed in order to complete the CFC phaseout. The Alliance
requests that long-lived HCFC production be phased-out in 2020. The petition also
addresses other issues penaining to the implementation of Title VI of the Clean Air Act
Amendments of 1990, including labeling deferrals, and identification of safe alternatives.
The Alliance For Responsible CFC Policy, organized in 1980, is a coalition of
U.S. companies that produce CFCs, HCFCs, and HFCs, as well as products and
processes that rely on these compounds. CFCs and HCFCs are used extensively as
refrigerants in air conditioning and refrigeration equipment, including motor vehicles; as
solvents in the electronics industry; as blowing agents for the manufacture of high
efficiency foam insulation and foam packaging; and as sterilants and medical aerosols in the
health industry.
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222
1994/1995 Membership List
Alliance for Responsible Atmospheric Policy
3M Comoany
A. Cook Associates. Inc.
Abbott Laboratones
Abco Refrigeration Supply Corp.
Acme • Miami
American Electronics Association (AEA)
Air Comfort Corporation
Air Conditioning Contractors of America
Air Conditioning & Refrigeration Institute
Air Conditioning Suppliers. Inc.
Air Products
Alliance Pharmaceutical Corporation
AlliedSignal
American Auto. Manufacturers Assoc.
American Frozen Food Institute
American Pacific Corporation
American Refrigerant Reclaim Corporation
American Thermaflo Corp.
American Trucking Associations
Amtrol. Inc.
Anderson Bros. Refrigeration Service. Inc.
Apex Ventilations
ARCA/MCA
Arizona Public Service Co.
Arjay Equipment Corporation
Arrow Air Conditioning Service Company
Arthur D. Little. Inc.
Ashland Inc.
Astro-Valcour Inc
Association of Home Appliance Manufacturers
AT&T
Ausimont USA
Automotive Consulting Group. Inc
Bard Manufacturing Co.
Beltway Heating & Air Conditioning Co. Inc.
Beverage-Air
Big Bear Stores Co.
Blue M Electric
Building Owners and Managers Association (BOMA)
Booth Refrigeration Services Conditioning
Bristol Compressors
c/o Moog Training Center
Camer Corporation
223
Celotex
Center for Appiiea Engineering
Central Coating Company, Inc.
Cetylite Industnes. Inc.
Chemical PacKaging Corp.
Chemtronics. inc.
Clayton Auto Air. Inc.
Commercial Refrigerator Manufacturers Association
Copeland Corporation
Day Supply Company
Oow Chemical U.S.A.
E.l. Dupont De Nemours and Company
E.V. Dunbar CO.
Eastman Kodak
Ebco Manufacturing
Electrolux/White Consolidated
Elf Atochem Nonh America. Inc.
Elliott-Williams Company. Inc.
Engineering & Refrigeration. Inc.
Falcon Safety Products. Inc.
FES Inc.
Flex-0-Lators. Inc.
Foam Enterprises. Inc.
Foamseal, Inc.
Food Marketing Institute
Foodservice & Packaging Institute
Ford Motor Company
Forma Scientific
Fox Appliance Parts of Augusta
Franke Filling, Inc.
Fras-Air Contracting
Free-Flow Packaging Corp.
Freightliner Corporation
Gardner. Carton & Douglas
Gebauer Company
General Electric Company
General Motors
Graineer
Gulfcoast Auto Air
H. C. Duke & Son. INc.
Hale and Dorr
Halocarbon Products Corporation
Halsey Supply Co.. Inc.
Harold Electnc Co.
Henry Valve Company
Highside Chemicals
Hill Refrigeration Corp.
Howard/McCray Refrigerator Co.. Inc.
224
Hugnes Aircraft Company
Hussmann Corooration
ICl Americas Inc.
IG-LO. Inc.
Illinois Supply Company
IMI Cornelius Company
Institute of Heating & Air Conaitioning Industries
Institute of International Container Lessors
Integrated Device Tecnnology inc.
International Assoc, of Refrigerated Warehouses
International Cold Storage Co.. Inc.
International Mobile Air Conditioning Assoc.
International Pharmaceutical Aerosol Coalition
Interstate Truckload Carriers Conference
Johnson Controls
Joseph Simons Co.
Keyes Refngeration. Inc.
King-Weyier Equipment Co.. Inc.
Kline & Company Inc.
Kraft General Foods
KYSOR WARREN
LaRoche Chemicals
Lennox Industries
Liggett Group Inc.
Lintem Corporation
Lohllard
Lowe Temperature Solutions
Luce. Schwab & Kase. Inc.
Malone and Hyde Inc.
Manitowoc Equipment Works
Marine Air Systems
MARVCO Inc.
Maytag Corporation
McGee Industries. Inc.
Mechanical Service Contractors of America
Merck & Co.. Inc.
Meti-Span Corporation
Miles Inc.
Mobile Air Conditioning Society
Monsen Engineering Co.
Montgomery County Public Schools
Moog Automotive Inc.
Moran, Inc.
225
Nat. Assoc. Of Plumoing-Heating-Cooiing Contractors
National Assn. of Food Eouipment Manufacturers
National;Automobile Dealers Association
National Refrigerants, Inc.
National Training Centers. Inc.
NO Slate Board of Refrigeration
Neaton Auto Products Mfg., iNc.
New Mexico Engineenng Res. Instit.-U of NM
North Colorado Medical Center
Northern Illinois Gas
Northern Research & Engineenng Corporation
Northland Corporation
Norton Company-Sealants Division
O'Brien Associates
Omar A. Muhtadi, Inc.
Omega Refngerant Reclamation
Orb Industries. Inc.
Patterson Frozen Foods. Inc.
Peirce-Phelps. Inc.
Pennzoil Company
Perlick Corporation
Polyisocyanurate Insulation Manufacturers Association (PIMA)
Polycold Systems Intemational
Premier Brands Ltd.
Ralph Wright Refrigeration
Rawn Company, Inc.
Reeves Refrigeration & Heating Supply, inc.
Refrigeration Engineenng. Inc.
Refrigerant Management Services
Refrigeration Service Engineers Society
Refron
Revco Scientific
Rhode Island Refrigeration Supply Comp, Inc.
Ritchie Engineering Co.. Inc.
Rite Off
RJR Nabisco
Robinair Division. SPX Corp
RSI Co.
Rule Industries. Inc.
SCM Glidco Organics
Scott Polar Corporation
Service Supply of Victoria. Inc.
Servidyne Inc.
Sexton Can Company
Sheeting, Metal. Air-Conditioning Contractors National Association (SMACNA)
South Central Co.. Inc.
226
Mr. ROHRABACHER. Thank you, Mr. Fay. We have about 8 min-
utes left before this vote — 7 minutes. Which means that I'll have
to run over and vote.
I'll be very interested in hearing your analysis of how the Senate
was able to vote 96 to zero and it had nothing to do with President
Gore's presentation to the Senate and to this House committee sev-
eral years ago.
Mr. Fay. I'll be happy to discuss it.
Mr. ROHRABACHER. So we'll be looking forward to that and we're
in recess, then, for, say, 15 minutes.
[Recess.]
Mr. ROHRABACHER. Someone was just telling me about the ozone-
eating radiator that he had seen and all these exciting things.
Now, Mr. Lieberman, you're the next witness. You seem to have
been the focus of several comments during the prior testimony. So
I'm looking forward to hearing your testimony.
Mr. Lieberman. I have a lot of friends. [Laughter.]
Mr. ROHRABACHER. GrO right ahead, Mr. Lieberman.
STATEMENT OF BEN LIEBERMAN, ENVIRONMENTAL RE-
SEARCH ASSOCIATE, COMPETITIVENESS ENTERPRISE INSTI-
TUTE, WASHINGTON, DC
Mr. Lieberman. Mr. Chairman, I'd like to thank you and the
other Members of the Subcommittee for the opportunity to speak
to you about ozone deletion and the CFC phaseout.
This is an issue that I have followed for two years as an environ-
mental research associate with the Competitive Enterprise Insti-
tute.
My comments will focus on the consumer impact of the acceler-
ated CFC phase-out. Unfortunately, this is a side of the issue that
has been largely ignored. For many years, the proponents of the
phase-out have dominated the debate with exaggerated claims of
environmental gloom and doom.
But now that the environmental threat is proving to have been
overstated, more people are starting to ask questions about how
much this will cost them.
In addition, millions of Americans have gotten a wake-up call in
the form of substantially higher air-conditioner repair bills, a trend
that will greatly increase in the years to come.
The air conditioning and refrigeration industry has become an
ally of the EPA in supporting the CFC phase-out. For the most
part, the refrigerant and equipment makers have already stopped
producing CFCs £ind CFC-using equipment and have switched to
production of substitutes.
At this point, they want CFCs out of the picture as soon as pos-
sible so they can start selling the substitute systems.
This is one environmentaJ issue where big government and big
industry are now on the same side. Both are lined up against the
consumer.
I would like to present some basic facts about what is occurring
and will continue to occur to air conditioning and refrigeration
costs.
The most costly category is motor vehicle air conditioners. There
are approximately 140 million car and truck air conditioners that
227
use CFC-12. I estimate that the cost of a car air conditioner repair
has increased about $100, on average.
Thus, the approximately 20 miUion that need repairs each year
cost $2 bilHon more annual. The cost will be even higher in future
years.
Another category of affected equipment is the refrigeration sys-
tems in approximately three-quarters of a million restaurants, food
stores, and other small businesses.
The added cost could reach several thousand dollars per facility,
one more onerous regulatory burden on small businesses.
Also affected are the chillers that air condition large office build-
ings, and residential refrigerators. In all, the total cost could reach
$100 billion, although there is some controversy over that, over the
next decade, or about $1000 per household.
I would also like to add that the cost burden of the CFC phase-
out is being disproportionately shouldered by American consumers.
There is a misconception that the costs of the CFC phase-out are
equally shared among the peoples of the world.
Although there is an international phase-out of CFCs, most of
the costs are being incurred here in the U.S. For one thing, the
U.S. has more affected equipment than any other nation and there
are several costly provisions that only affect Americans.
Also, developing nations such as China, India, and Mexico, have
a ten-year delay in phasing out CFCs.
Further, unlike the U.S., many other nations are not strongly en-
forcing the phase-out. For example, the evidence, the anecdotal evi-
dence I've hard is that black market CFCs are readily available
throughout much of western Europe and at prices lower than in
the U.S.
Thus, the argument that this is a globally-shared burden is spu-
rious and unilateral relief for American consumers would not be
unfair.
The costs have been exacerbated by the acceleration of the CFC
phase-out from the January 1, 2000 deadline in the Clean Air Act,
to the end of this year.
This is true for several reasons.
First, for the large volume of CFC equipment currently in exist-
ence, the accelerated phase-out will interfere with its continued
use. Many perfectly good systems will have to be prematurely re-
placed or retrofitted when CFCs become scarce, probably in 1997,
maybe 1998.
On the other hand, a slower phase-out would have allowed most
existing systems to live out their useful lives and then be replaced
in due course by non-CFC systems.
In addition, the abrupt phase-out of CFCs is resulting in the in-
troduction of substitute refrigerants and equipment being rushed
into service with minimal field testing and many technical bugs yet
to be worked out.
Consumers would be better off if they could continue using their
CFC systems until the new systems have been improved upon. But
the accelerated phase-out denies them this option.
Further, many have raised environmental concerns about several
leading CFC substitutes. For example, HCFCs, which are now used
as replacements for CFCs in several applications, are themselves
228
being considered for an accelerated phase-out by the parties to the
Montreal Protocol, based on the belief that they also contribute to
ozone depletion.
HFC-134a, the most common substitute, has been called a con-
tributor to global warming. And recently, a scientific study reported
that the breakdown products of several CFC-substitutes may dam-
age wetlands.
There are also safety and toxicity concerns that have not been
adequately addressed. And whenever asked for firm assurances
that these substitutes won't also be later restricted, EPA has al-
ways balked.
Thus, it may well be that after consumers are forced to endure
the abrupt and costly phase-out of CFCs, they will be subject to a
second phase-out for the CFC substitutes that were rushed into use
and then later found to be environmentally unacceptable as well.
These problems could be substantially reduced by allowing a few
more years of limited CFC production.
The Doolittle Bill would return the phase-out deadlines to those
in the 1990 Clean Air Act, allowing limited CFC production until
the year 2000.
We have heard testimony from some scientists that this small
amount of additional CFC production, really about one percent
compared to what's already out there, will make very little dif-
ference from an environmental standpoint. But it would be enough
to save American consumers billions of dollars. It will enable those
with CFC equipment to continue using their systems with CFCs for
at least a few more years, by which time we will better know which
substitute refrigerants are technically and environmentally accept-
able.
This will avoid the problem of expensive false starts. It will also
spare equipment owners from having to rely on black market and
recycled refrigerants which are lacking in quantity and quality, by
providing a supply of new and pure refrigerants.
Thank you.
[The complete prepared statement of Mr. Lieberman follows:]
229
Testimony of Ben Lieberman
Environmental Research Associate, Competitive Enterprise Institute
before the
Subcommittee on Energy and Environment of the Committee on Science
U.S. House of Representatives
September 20, 1995
Mr. Chairman, I would like to thank you and the other
members of the subcommittee for the opportunity to speak to you
about ozone depletion and the CFC phaseout. This is an issue
that I have followed for two years as an environmental research
associate with the Competitive Enterprise Institute.
My comments will focus on the consumer impact of the
accelerated CFC phaseout. Unfortunately, this is a side of the
issue that has been largely ignored. For many years, the
proponents of the phaseout have dominated the debate with
exaggerated claims of environmental gloom and doom. The widely
publicized predictions of skin cancer and cataract epidemics,
crop failures, destruction of the ocean food chain, animals going
blind, and so forth, have tended to overshadow concerns about the
costs of eliminating CFC production. But now that the
environmental threat is proving to have been overstated, more
people are starting to ask questions about how much this will
cost them. In addition, millions of Americans have gotten a wake
up call in the form of substantially higher air-conditioner
repair bills, a trend that will greatly increase in the years to
230
come. For the first time, the cost side of the CFC phaseout is
getting the attention it deserves.
To the limited extent the EPA has addressed the costs, they
have not been honest with the American people. Their extremely
low cost estimates have no basis in reality, and cannot stand up
to scrutiny. Also, the air-conditioning and refrigeration
industry has become an ally of the EPA in supporting the
accelerated CFC phaseout. For the most part, the refrigerant and
equipment makers have already stopped producing CFCs and CFC-
using equipment and have switched to production of substitutes.
In effect, the impending phaseout has forced them to market
products that cannot compete with the proven reliability of CFCs.
At this point, they want CFCs out of the picture as soon as
possible so they won't have to deal with the problem of
convincing consumers to abandon existing CFC systems that are
serving them so well for expensive substitutes that have no track
record. A return to CFC production, even a temporary one, will
cost the industry money, because it will enable millions of
owners of existing CFC-equipment to continue using their systems
for several more years. And every piece of CFC equipment that
stays in use is one less piece of new equipment that gets sold.
It is not surprising that industry groups oppose any additional
CFC production and tend to downplay the problems for consumers
caused by the accelerated CFC phaseout. This is one
environmental issue where big government and big industry are now
on the same side. Both are lined up against the consumer.
231
since both the EPA and industry have not been forthcoming
regarding the real costs of the phaseout, I would like to present
some basic facts about what is occurring and will continue to
occur to air-conditioning and refrigeration costs. Although the
bulk of the consumer impact will take place in the next few
years, consumers have already been affected to the tune of
several billion dollars, and a number of troubling problems have
begun to emerge. I believe that the accelerated CFC phaseout may
become the single most expensive environmental measure ever.
There are several categories of air-conditioning and
refrigeration equipment impacted by the phaseout. The most
costly category is motor vehicle air-conditioners. There are
approximately 140 million car and truck air-conditioners that use
CFC-12. Most owners of pre-1994 cars or trucks are affected.
Model year 1994 and newer vehicles use a substitute refrigerant,
HFC-I34a. I estimate that the cost of a car air-conditioner
repair has increased about $100 on average, thus the
approximately 20 million that need repairs each year cost $2
billion more annually. The cost will be even higher in future
years, particularly if CFCs become prohibitely expensive or
unavailable, which many predict to occur by 1997 or 1998. If
this happens, owners will have to retrofit their vehicles to use
a CFC-substitute. Retrofit costs vary from model to model, but a
typical cost is $200 to $500. And there are serious questions as
to how long a retrofit will last.
232
Another category of affected equipment is the refrigeration
systems in approximately three quarters of a million restaurants,
food stores, and other small businesses. The equipment used in
these establishments already costs more to repair, due to higher
refrigerant and labor costs. And if CFCs become scarce by 1997
or 1998, much of it will have to be prematurely replaced or
retrofit, which can cost thousands of dollars - one more onerous
regulatory burden on small businesses.
Another affected category of equipment is the chillers that
air-condition large buildings. These systems are very expensive
to purchase and install, and the phaseout will necessitate a
number of premature replacements and costly retrofits of existing
CFC systems over the next decade.
Residential refrigerators are also affected. Because of
their importance in our lives and widespread use, even a small
increase in the costs of non-CFC refrigerators, or decline in
their quality and reliability, can have a substantial effect.
The phaseout will also affect states and municipalities, as
well as the federal government. Millions of pieces of air-
conditioning and refrigeration equipment are publicly owned.
From the refrigeration systems in school cafeterias to public
hospitals to air-conditioned federal buildings, governments are
also going to pay more and taxpayers will foot the bill.
In all, the total costs could reach $100 billion over the
next decade, or about $1,000 per household. Beyond the dollar
costs is the impact on human health. Air-conditioning, far from
233
being a luxury item, is a life saving technology, particularly
during heat waves. Refrigeration is also important in providing
a safe and inexpensive food supply and plays a vital role in
medical care. Regulations that raise the cost and lower the
availability and quality of air-conditioning and refrigeration
could impact the health of our nation.
I would also like to add that the cost burden of the CFC
phaseout is being disproportionately shouldered by American
consumers. There is a misconception that the costs of the CFC
phaseout are equally shared among the peoples of the world.
Although there is an international phaseout of CFCs, most of the
costs are being incurred here in the U.S. For one thing, the
U.S. has more affected equipment than any other nation. In
contrast, the Scandanavian countries, which have taken the lead
in demanding stringent phaseout deadlines, have much less to lose
because they have far less air-conditioning equipment. Also,
developing nations such as China, India, and Mexico have a ten
year delay in phasing out CFCs, and several nations, including
Russia, have indicated that they will not comply with the current
deadlines. In addition, there are provisions that only affect
Americans, like the onerous EPA regulations requiring expensive
and time consuming procedures during repairs of air-conditioning
and refrigeration equipment, as well as the heavy excise taxes on
CFCs. Further, while our government is trying hard to crack down
on the burgeoning black market in CFCs, other nations are making
scant enforcement efforts. For example, the anecdotal evidence
234
I've accumulated suggests that black market CFCs are readily
available throughout much of Western Europe, and at lower prices
than in the U.S. Thus, the argument that this is a globally
shared burden is spurious, and unilateral relief for American
consumers would not be unfair.
The costs have been exacerbated by the acceleration of the
CFC phaseout from the January 1, 2000 deadline in the original
1990 amendments to the Clean Air Act, to the January 1, 1996
deadline we have right now. This is true for several reasons.
First, for the large volume of CFC equipment currently in
existence, the accelerated phaseout will interfere with its
continued use. Many perfectly good systems will have to be
prematurely replaced or retrofit when CFCs become scarce. On the
other hand, a slower phaseout would have allowed most existing
CFC systems to live out their useful lives, and then be replaced
in due course by non-CFC systems. With automotive air-
conditioners, for example, normal fleet turnover results in 10%
of older cars going off the road each year. And since new cars
no longer use CFCs, we would have seen a steady decline in the
number of CFC-using motor vehicle air-conditioners without a
draconian phaseout and its accompanying costs.
In addition, the abrupt phaseout of CFCs is resulting in the
introduction of substitute refrigerants and equipment being
rushed into service with minimal field testing and many technical
bugs yet to be worked out. Few knowledgeable engineers believe
these new systems will be as reliable and last as long as their
235
CFC-using counterparts. Consumers would be better off if they
could continue using their CFC systems until the new systems have
been improved upon. But the accelerated phaseout denies them
this option.
Further, scientists and environmentalists have raised
concerns about several leading CFC substitutes. For example,
HCFCs, which are now used as replacements for CFCs in several
applications, are themselves being considered for an accelerated
phaseout by the parties to the Montreal Protocol, based on the
belief that they also contribute to ozone depletion. HFC-134a,
the most common substitute, has been called a contributor to
global warming. And recently, a scientific study reported that
the breakdown products of several CFC-substitutes can accumulate
in wetlands, and concluded that the ecological consequences could
be serious. There are also safety and toxicity concerns that
have not been adequately addressed. And, whenever asked for firm
assurances that these substitutes won't also be restricted, EPA
has always balked. Thus, it may well be that after consvimers are
forced to endure the abrupt and costly phaseout of CFCs, they
will be subject to a second phaseout for the CFC substitutes that
were rushed into use and then later found to be environmentally
unacceptable as well. The costs of such false starts could add
billions to the phaseout's ultimate price tag.
Also, the accelerated phaseout is going to become far more
costly than expected because refrigerant recovery and recycling,
which is mandated by the law and the EPA regulations, is turning
236
out to be a disappointment. Despite optimistic statements by the
EPA that recovery and recycling of exisiting CFCs will provide an
ample supply to meet future damand, it is clear that it will fail
to do so. Thus far, the quantity and quality of recycled
refrigerant is far below expectations. In some cases, recycled
CFCs are so contaminated that they can actually damage a system.
The trade press is replete with articles such as "Recovered
Refrigerant: Where is It?" (Air Conditioning, Heating, and
Refrigeration News, May 16, 1994) . And the fact that there is a
growing black market is also evidence that recycled refrigerants
are not sufficient to meet demand.
These problems could be substantially reduced by allowing a
few more years of CFC production. The Doolittle Bill would
return the phaseout deadlines to those in the 1990 Clean Air Act,
allowing limited CFC production until the year 2000. We have
heard testimony from scientists that this small amount of
additional CFC production will make very little difference from
an environmental standpoint. But it would be enough to save
American consumers billions of dollars. It will enable those
with CFC ec[uipment to continue using their existing systems with
CFCs for at least a few more years, by which time we will better
know which substitute refrigerants are technically and
environmentally acceptable. This will avoid the problem of
expensive false starts. It will also spare equipment owners from
having to rely on black market and recycled refrigerants which
237
are lacking in quantity and quality, by providing a supply of new
and pure refrigerant.
In conclusion, the accelerated phaseout of CFCs will be very
costly to consumers, particularly over the next few years.
Allowing an additional amount of limited CFC production until
2000 would be environmentally inconsequential, but would greatly
reduce the costs to consumers. Not doing so may well lead to a
consumer backlash.
238
CEI
CEI
Environmental
studies program
CKI
THE fflGH COST OF COOL
CKI
The Economic Impact of the CFC
Phaseout in the Uniied States
CKI
CT^J
Ben Lieberman
CKI
CKI
June 1994
CKI
COMPETmVE ENTERPRISE INSmVTE
1001 Connecticut Avenue NW. Suite 1220
Washington. DC 20036
(202)331-1010 Fax:(202)331-0640
239
The Competitive Enterprise Institute
The Competitive Enterprise Institute (CEi) is a pro-market public policy group
committed to advancing the principles of free enterprise and limited government
Founded in 1984 by Fred L. Smith, Jr., CEI emphasizes the mariceting and imple-
mentation of classical liberal ideals.
CEI utilizes a five-point management approach to affecting public policy: analysis,
education, coalition building, advocacy and litigation. Its purpose is to advance
the free-mari(et agenda, believing limited government and competition best serve
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enue Code, CEi relies entirely on donations from corporations, foundations, and
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For more information contact
Competitive Enterprise Institute
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Suite 1250
Washington. DC 20036
202/331-1010 >
240
THE HIGH COST OF COOL
The Economic Impact of the CFC Phaseout
Ben Lieberman
EXECUTIVE SUMMARY
Chlorofluorocarbons (CFCs) are an imponant class of compounds. They have an impact on
the life of nearly every American. Yet, as a result of environmental fears, their production will
soon be eliminated - by the year 1996. In making this decision, little consideration was given to the
costs of eliminating such a widely used class of compounds over a relatively short period of time.
This study examines the probable economic cost of the CFC phaseout on the refrigeration
and air conditioning sector in the United States. The estimated cost of the CFC phaseout is $44.5 to
S99 4 billion over the next decade. This estimate breaks down as follows (figures in billions):
• Vehicle air conditioners — S28.0 - S42.0
• Energy consumption — S 0 - $32. 1
• Domestic refrigeration — $ 4.0 - $ 8.0
• Commercial refrigeration — $ 3.0 - $ 5.4
• Chillers — $ 4.4.$5 0
• HCFCs & HCFC Equipment — $ 5 1 - $ 6.9
Compliance with the law will impose large up-front costs on businesses and individuals. Much
equipment will need to be replaced or modified (retrofitted).
After decades of fine-tuning and extensive field experience, air conditioning and refrigera-
tion equipment using CFCs has become very reliable. In contrast, most CFC replacements are new,
and manufacturers are still near the bottom of the learning curve in making the massive technologi-
cal changes necessary.
Because of the accelerated phase-out, which provides a limited time frame in which to end
dependence on CFCs, non-CFC systems are being rushed into use, despite many unsolved problems.
In effect, a multi-billion dollar field test of experimental equipment is being conducted at consumer
expense. The frequency of break downs, and the costs of repairs can be expected to increase for
many applications.
The CFC phaseout may well be the single most expensive environmental measure taken to
date During the policy debate, the costs were underemphasized to the point that they never became
an important factor. The impact on consumers was scarcely considered. It may be too late to
reverse course on the CFC phaseout, but it can serve as a lesson for the future.
241
THE HIGH COST OF COOL
The Economic Impact of The CFC Phaseout
In the United States
byBenLiebennan
INTRODUCTION
Chlorofiuorocaibons (CFCs) are an important class of compounds. They
are the refrigerants used in over S 100 billion worth of air-conditioning and
refrigeration equipment in the US. They have an impact on the life of nearly every
American, as many people own CFC -using equipment and purchase goods and
services that rely on CFCs.
As a result of environmental fears, their production will soonbe eliminated.
A number of scientists have argued that CFCs and other compoundsdeplete the
earth's ozone layer.' Accordingtothetheory.CFCmoleculesthatescapeintothe
atmosphere at ground level eventually rise to the upper atmosphere (stratosphere),
where they are broken down by sunlight and release their chlorine atoms. The
chlorine atoms then destroy ozone molecules, leading to depletion ofthe strato-
sphericozone layer Since the ozone layerpartiallyshidds the earth from incoming
ultraviolet radiation, itsdepletion is prediaed to lead to an increase in ultraviolet
radiation reachingground level.' Because increased ultraviolet radiation levels
could adversely affect human health and the environment, the Congress and the
international community have outlawed the production of CFCs by the end of
1995
In making this decision, there was littleconsideration given to the costs of
eliminating such a widely used class of compounds over a relatively short period
oftime IntheU S..thesecostswiUbebetween$44.5 to S99.4 billion over the
next decade for refiigeration and air-conditioning alone. This amounts to
approximately S44S to S994 per household. These costs should have been taken
into account during the CFC phaseout decisionmaking process.
The federal go venunent, once it chose to embark on the accelerated CFC
phaseout, has tried to minimize the issue of the costs to the public. While
overstating the dangers of ozone depletion in numerous reports, hearings, and
press conferences, agency officials and legislators have often underemphasized
the economic consequences and human impact of eliminating CFC production
by 199S ' The few studies that estimate the costs tend to understate them,
while overstating the environmental bene6ts of eliminating CFCs.* As a result.
CFCs have an
impact on the life
of nearly every
American.
Utbtrman: The High Cost of Cool
Pigel
242
There was little
consideration
given to the costs
of eliminating
such a widely used
class of com-
pounds over a
relatively short
period of time.
the public has accepted the CFC phaseout in near total ignorance of the impact it
will have on them.
This paper will attempt to provide a realistic assessment of the costs in the
U.S. ofeliminating CFC production by 1995. It will be limited to the impact on
refrigeration and air-conditioning', and will emphasize the costs that, directly or
indirectly, will be imposed on American consumers over the courseofthe next ten
years.
THE CURRENT STATE OF THE LAW
Both international and U.S. lawrestriatheproductionofCFCs.* In 1987,
the international community responded to fears of global ozone depletion by
ratifying the Montreal Protocol on Substances That Deplete the Ozone Layer
(Montreal Protocol). Itwas signed initially by 24nations, including theUS. and
most major CFC producers. Today the Montreal Protocol has 1 23 signatories.
It originally called for an eventual SO percent reduction in global CFC production,
but has since been amended to require a total phaseout, except for "essentiaT uses,
by the end of 1 995 for developed nations and 2005 for developing nations.'
Domestically, the Congress included provisions to the Clean Air Aa
Amendments of 1990, which set production limits on CFCs, culininating in a
total phaseout by the year 2000. In February 1992, the phaseout was
accelerated in response to a NASA press conference, where several scientists
predicted a severe depletion of the ozone layo- over North America during the
winter.' The Seruteunanimously passed an amendment urging president Bush to
roo ■
-«00-r'
I 400 -K
200-
100 ■
U.S. PRODUCTION OF CFC-ll AND CFC-12
1987 - 1997
;z=?i
.^^IPI
■"iiiiTn
^!^=P^
\/, ^ / ^^d^
1»I7 19il 1919 1990 1991 199J 1991 1994« I99S* I99«« I997*
•ToialCPC >r»<iaMsliaiuia<«iicn«U 1 li« Yt«r
SOL'KCE:/lir-Ca>i<ineMi>ig, HtaaKgandR^hfraiKmNtwi
Page 2
Litberman: Tht High Cost of Cod
248
moveupthephaseoutdateto 1995, towhichthcpresident agreed.' Afewmonths
later. NASA admitted that their prediction was incorrect, but the accelerated
phaseout was unaffected. '"
In response to Congress, the EPA recently promulgated the regulation that
outlines the phaseout. ' ' Generally, CFC productionis limited to 25 percent of 1 986
production levels for 1994 and 1995, with a complete end to production on
January 1. 1996 " Estimates ofpast and projected CFC production in the U. S.
are displayed in the chart above. In addition, a related class of compounds called
HCFCs is being phased out under a slower timetable. " The EPA has also imposed
regulations regarding the manner in which air-conditioning and refrigeration
equi pment is serviced and disposed of, in an attempt to reduce the atmospheric
release of existing CFCs. '*
CFCs are rapidly
becoming scarce.
AN OVERVIEW OF THE COSTS
Before analyzing the effect of the phaseout on specific end uses, it is
worthwhile to take an overall view ofits impaa. Compliance with the law will
impose largeup-front costs on businesses and individuals, as much equipment will
need to be replaced or modi-
fied (retroiined) In addition.
ESTIMATED CFC PHASEOUT COSTS
REFRIGERATION AND AIR-CONDITIONING
1994 through 2003
(figures in Sbillions)
Cost
there will be inaeases in ongo-
ing operational expenditures
as a result of higher
maintainance costs, refinger-
ant costs and energy consump-
tion This will add as much as
$9 94 billion annually overthe
next decade to the cost of
meeting America' s refrigera-
tion and air-conditioning needs.
The breakdown of the costs
over the next decade assessed
in this paper is displayed in the
table at right and the chart
below
Equipment Costs
In the US, there is
approximately $135 billion
worth of air<onditioning and
refrigeration equipment in com-
mercial and domestic use.'' Much ofthis equipment has a usefiil life of 10 to 25
years, needs additional refiigerant to make up for leakage over time, and is not
designed to work wnth non-CFC refiigerants.'* Because CFCs are rapidly
becoming scarce, much equipment will have to be prematurely replaced or
Ltbtrman: The High Cosi of Cool
Range
Vehicle Air-Conditioners
28.0 - 42.0
Energy Consumption
0-32.1
Domestic Refrigeration
4.0- 8.0
Commercial Refrigeration
3.0- 5 4
ChiUen
44-5.0
HCFCs and HCFC Equipment
5.1-6.9
TOTAL
44.5-99.4
Note: The following ire not included in the tbove analysis: refrigerated
transportauon, indusinal refrigerauon, medical and laboratory equipmenc,
dehumidificrs, vending rinchinei. water coolers, dnnking founuins.
Page 3
244
CFC PHASEOUT COSTS
ESTIMATED DISTRIBUTION
QjTBbc RA^Axn
retrofitted to use CFC alternatives.
Billionsof dollars in additional equip-
ment and installation outlays will be
required to maintain the status quo.
Even after the current base of
equipment is replaced, there may be
ongoingincreases in equipment costs.
There are some indications that the
alternative systems will havea shorter
useful lifethan their CFC-usingcoui>-
terparts, but it is difficult to icno w for
certain as non-CFC equipment has
only recently come into use. Al-
though the potential costs of more
frequent replacements could be high,
they cannot be accurately estimated
at this time and will not be included in
the total accounting.
OPERATIONAL COSTS
In effect, a multi-
billion dollar field
test of experimen-
tal equipment is
being conducted
at consumer ex-
pense.
Maintenance
After decades offine-tuning and extensive field experience, air-condition-
ingand refiigeration equipment usingCFCshadbecomeve:yreliable. In contrast,
most CFC replacements are new, and manufacturers are still near the bottom of
the learning curve in making the massive technological changes necessary.
Properly matching equipment with these new refiigerants will take several more
years. This task is fijrther complicated by the faa that many non-CFC refrigerants
have inherent chemical and thermodynamic properties that make them difficult to
manage.
Under ordinary circumstances, extensive research and development
would be completed by industry prior to new equipment being introduced in
the market. However, because of the accelerated phaseout, which provides
a limited time firame in which to end dependence on CFCs, non-CFC systems
are being rushed into widespread use, despite many unsolved problems. In
effect, a multi-billion dollar field test of experimental equipment is being
conducted at consumer expense. The frequency ofbreakdowns, and the costs
of repairs can be expected to increase for many applications.
Further, the rapid introduaion of numerous new refrigerants has
thrown the refirigeration and air-conditioning service industry into a state of
confusion. In the last few years, no less than 1 0 new refrigerants have come into
use, and more are on the way. '^ Some have unique equipment requirements and
servicing needs, which are currently being discovered through trial and error. "
Page 4
Liebtrman: The High Coil of Cool
245
Further, because some of the new refrigerants are chemically incompatible with
others, service equipment that comes in contart with one refrigerant (for example
recovery devices or gauges) may cause contamination iflater used on asystem with
a different refrigerant. Unless servicemen own and maintain several sets of
dedicated equipment, refrigerant cross-contamination will become a serious
problem
The situation is so complex that even skilled servicemen admit that they are
of^en not certain as to the proper procedure. Costly mistakes made during
installation, routine maintenance, and repairs will be common for many years,
imposing significant costs on equipment owners.
Also, refrigerant recovery rules, requiring servicemen to take measures to
prevent refrigerant leakage during servicing, and rules requiring leak detection and
repair, are time consuming and require expensive equipment, adding to the'costs
of repairs and maintainance "
Air-conditioning and refrigeration servicing has become more costly."
Some servicemen estimate that they will be charging clients about 25 percent more
than they had previously However, the total increase in maintenance costs cannot
be determined at this time, as most of these costs are incurred after equipment has
been in use for a few years, and non-CFC equipment has only recently made
inroads into the American market. Because of the uncertainties, these costs will
not be included in the total accounting, except in those cases where it is specifically
noted.
Refrigerant Use
Before the phaseout took effect, the market price of the most common
types of CFC refrigerants, CFC-11 and CFC-12. was less than $1.00 per
pound wholesale. Today, as a result of production limits and excise taxes, they
cost approximately S8 GO to SIO 00 per pound at the wholesale level, and up
to twice that for some retail users." This amount is expected to rise
considerably in the months and years ahead. In 1994 and 199S, the quantity
of CFCs allowed to be produced is about 180 million pounds annually, but
based on recent years, considerably more than that will be needed. ° After
January 1, 1996, when all production ends, cost increases will further
accelerate due to limited supplies." Predictably, a black market in CFCs is
developing."
Refrigerant recovery and subsequent recycling orreclamation, though
required by law, is not likely to make up for the shortfall. There are limitations
on how much refrigerant can be recovered and reused.** Also, compliance has
not been widespread, particularly among those servicing equipment with a
small refiigerant charge."
The leading replacement refrigerants are also expensive. Unlike CFCs,
the patents on which have long since expired, many of these new compounds are
still underproprietary protection." Others are more expensive to produce. The
Costly mistakes
made during
installation, rou-
tine maintenance,
and repairs will be
common for many
years.
A black market in
CFCs is develop-
ing.
Ueberman: Tht High Cost of Coot
PigeS
246
In nearly every
case, thephaseout
ofCFCs will re-
sult in higher costs
and decreased
performance.
most common replacement, hydrofluorocarbon- 1 34a{HFC- 1 34a), costsat least
$7 00 per pound. " In addition, some replacement refrigerants require expensive
lubricants and additives in order to function properly. Cheaper alternatives, such
as ammonia and hydrocarbons, have limitations — flammability, toxicity, regula-
tory barriers — that will take several years to overcome, and are not likely to be
widely used in the U S . in the near future.
Before the stringent production restrictions were in effect, the US
produced and consumed approximately 650 to 700 million pounds of CFCs
annually, at least 300 million of which were used as refrigerants." Conserva-
tively estimating a $5.00 per pound increase in the current cost of CFCs and
alternatives over the pre-phaseout cost of CFCs, an additional $1.5 billion per
year will be spent on refrigerants. Most of these costs are included in the costs
of new equipment and retrofits, and are not separately discussed.
Energy Use
Air-conditioning and refrigeration are energy intensive, consuming
about 28 percent of the nation' s elearicity . '^ CFCs are currently used in many of
these applications. Their replacement has raised concerns about the impact on
energy consumption.
As refrigerants, CFCs are relatively energy efiScient. Their thermody-
namic properties — thermal conductivity, latent heat of vaporization, boiling
point — are nearly ideal, for a variety of applications. In contrast, many of the
leading replacements, such as HFC- 1 34a, are not as well suited, and a loss in
energy efficiency (relative to comparable CFC-using equipment) is unavoid-
able." In addition to thermodynanuc efficiencies, there may be other problems
with non-CFC systems that will lead to greater energy use."
One hypothetical estimate of the annual increase in overall electricity
use resulting from a CFC phaseout gives the range of 1 3 to 94 billion kWh/yr, or
(assuming $ 0.06 per KWh) $0.78 to $5.64 billion dollars." The middle ofthis
rangeamounts to an additional energy cost of53 21 billion per year.
Other recent studies bythe EPA, DOE and the alternatives industry found
little or no energy penalty. ^ They compared the efficiencies of new alternative
systemsutilizing optimized engineering design with theold and infenorty equipped
CFC systems they are replacing. Relative efficiencies of comparable CFC and
non-CFC systems were not considered." The energy efficiency gains in new
equipment are due to technological advances largely unrelated to the refrigerant
chosen, although the CFC phaseout may have provided the impetus for immediate
implementation of these costly improvements. In effect, the e£5ciency gap between
new non-CFC and old CFC systems is being narrowed, and in some cases
eliminated, but at the expense ofhigher equipment costs.
Nonetheless, the gap between comparable CFC and non-CFC systems
persists. However, the extent of this gap is difficult to determine, as the energy
efficiency of new non-CFC equipment is currently being improved, and the
Page 6
Uebentum: The High Coil of Cool
247
efficiency of comparable CFC systems can only be speculated, as CFCs are no
longer being used in stste of the an equipment In addition, the CFC phaseout has
accelerated the retirement rates for old, inefiRcient systems. For these reasons, it
is hard to estimate what energy consumption would have been without the CFC
phaseout, and what it will be with the phaseout.
For the purposes of this study, the assumed range of increased annual
energy expenditures is SO to S3 2 1 billion, or SO to $32 I billion over the next
decade Thelowendofthisrangeassumesthatenergyuseforair-conditioningand
refrigeration will be no different than if there there been no CFC phaseout. The high
end, which represents the middle ofthe range discussed previously, estimates a
penalty of about 2 percent of total energy consumption.
THE DVIPACTON SPECIFIC END USES
The higher initial and ongoing costs discussed above will affect most kinds
of refrigeration and air-conditioning applications. In nearly every case, the
phaseout of CFCs will result in higher costs and decreased performance. The most
heavily affected applications wiU each be discussed separately.
Vehicle Air-Conditionen
Americans own approximately 1 40 million automobiles and trucks that
use CFCs in their air-conditioners.^ Unless willing to do without air-conditioning,
these owners are faced with two choices — continue using CFCs, or retrofit their
system to use an alternative refrigerant. Either choice entails increased costs.
Continue UsingCFCs:
Generally, vehicle air-conditioners run without problems for the first few
years, and then need servicing once every two or three years thereafter. The most
common problem is refrigerant leakage. Approximately 20 million cars and trucks
are brought in for air-conditioner servicing each year."
The accelerated phaseout already has increased the cost of servicing.
Servicemen are required to comply with refrigerant recovery rules in order to
reduce the amount of refrigerant that escapes during servicing.'* This takes
as much as a half hour and requires equipment costing about SI, 000 As a
result, labor costs for air-conditioner servicing have gone up.
The cost ofthe refrigerant, CFC- 12, has also increased from under
SI 00 per pound to as much as SIO.OO wholesale and about twice that retail.
.\ vehicle may need up to three pounds to be fully operational. The cost is
expected to rise further, particulariy in 1996 when all production ends.
It is nowillegal to sell small cans of CFC- 1 2to the public, which were used
to recharge vehicle air-conditioners." Consideringthat 60 to 80 million pounds
of refrigerant were sold in these cans, it is reasonble to assume that millions of
people recharged their o\yn vehicle air-conditioners, at minimal cost.'' They are
no longer able' to do so Now tlfey are forced to take their vehicles to an EPA-
Approximatefy 20
million cars and
trucks are brought
in for air-condi-
tioner servicing
each year
Uebtrman: The High Cost of Cool
Page 7
248
The auto industry
has spent several
hundred million
dollars to redesign
vehicle air-condi-
tioning systems.
certified mechanic or dealer whenever their air-conditioner needs servicing, and
pay the market price for refrigerant and labor.
As a result, recharging an air-conditioner low on refrigerant, which cost
between $20 and $40 as recently as 1991 (and just a few dollars for do-it-
yourselfers), currently averages approximately S 1 00.*' This figure will increase,
possibly doubling by 1996, if CFC-12 costs continue their present trends.
Performing repairs on a system, such as fixing a leak, averages S26S, a20 percent
increase over the 1 99 1 average." This amount is also likely to increase with time.
Also, the number of vehicle owners being persuaded by servicemen to spend
considerably more to repair leaks rather than "top oS" (adding lost refiigia-ant
without repairing the leak) will inaease, in order to avoid the possibility of further
CFC- 1 2 losses in the fijture.*' In Florida and parts of California, leak repair is
required by state law.
Retrofit:
CFC-using air<onditioneis can be modified to use an alternative refrig-
erant, HFC- 134a. However, this is an expensive changeover, requiring the
replacement of several components, including the hoses, safety valve, 0-ring seals,
drier, and possibly the condenser, as well as a thorough flushing of thesystem to
remove all traces of CFC- 1 2 and mineral oil, which act as contaminants in the
presence ofHFC- 134a. The estimated average cost ofa retrofit is S433.** Also,
there are unanswered questions as to the performance and reliablity of retrofits.^
It is unlikely that many consumers will choose the retrofit option, unless CFC- 1 2
becomes prohibitively expensive ortotally unavailable.
Tptal CgStS F«?r Exiting VghitlWi
Assuming the 1 40 ntillion CFC-using vehicles need an average of two
more air-conditioner repairs or recharges before they are retired over the
course of the next ten years, and each servicing averages S 1 00 to S 1 SO more
than a comparable pre-phaseout servicing, the increased cost will be S28 to
S42 billion over the next decade.** The total will be even higher if difiSculties
in obtaining CFC- 1 2 force a large number of people to retrofit their vehicles.
The option of simply not repairing an inoperative CFC-12 air-conditioner is
also costly, as it will reduce the resale value of a vehicle by several hundred
dollars."'
New Vehicles:
New car and truck air-conditioners are now designed to use HFC-
134a. Introduced in a few models in 1992 and 1993, HFC-134a air-
conditioners will predominate in 1994 models. The auto industry has spent
several hundred million dollars to redesign vehicle air-conditioning systems
and retool assembly lines to accommodate the changes. Eventually, these costs
will be passed on to consumers in one form or another.
Pages
Liebtrman: The High Cost of Cool
249
It is unlikely that HFC- 1 34a systems will be as reliable as CFC-12
systems*' High failure rates after several years in use may be common. Unlike
CFC-using systems, which (excepting minor repairs and occasional re-
charges) often lasted as long as the vehicle, a number of HFC- 1 34a air-
conditioners will probably need a major repair during the vehicle's useftjl life. If
so. owning and maintaining a new HFC- 1 34a air-conditioner for the life of the
vehicle will cost sevieral hundred dollars more than a comparable pre-phaseout
CFC system Any additional costs will become apparent only after the new HFC-
134a air-conditioners have been subjected to a few yearsof use.** Because these
costs are speculative, they are not included in the total accounting forthis paper.
Domestic Refigeraton
There are abflyrMftMban refrigerators in domestic use m the U.S."
Nearly every household has at least one. They are reasonably priced and
extremely reliable, often providing 15 or more years of trouble-free service.
Until recently, nearly all used CFC-12 as their refrigerant. The phaseout will
have relatively little effect on these refiigerators. as less than 5 percent ever
require servicing due to refrigerant leakage.
However, refrigerator manufacturers are already preparing for the
phaseout. As a result of CFC-12 shortages and price increases, several
refrigerator manufacturers have begun to make the transition to non-CFC
refrigerators, well ahead of the January 1 , 1 996 phaseout date. By that time,
all newly manufactured refrigerators will be CFC-free.
As with vehicle air-conditioners, the alternative refiigerant of choice
for new domestic refHgerators is HFC- 134a." Although it is too early to
determine the price of these new refrigerators, at least one introductory model
is priced S 1 00 higher than a comparable CFC refirigerator, most ofwhich range
from $500 to $ 1 ,500, depending on the brand name and features." Assuming
a S50 to SI 00 increase per reftigerator, the nearly 10 million domestic
refrigerators (and stand-alone fi'eezers) sold each year will cost an additional
$0 5 to $10 billion.'*
Assuming HFC- 134a refrigerators predominate beginning in 1996, the
cost over the next decade will be S4.0 to $8.0 billion.
HFC- 1 34a refrigerators may use more energy than an equivalent CFC
system ** Like vehicle air-conditioners, ^FC-134a refrigerators are unlikely
to be as reliable and long-lasting as their CFC-using counterparts. " Expensive
repairs may be common, some necessitating replacement, particularly after
about 8 years of use. Because the first HFC- 1 34a refHgerators are only a few
years old, there is no direct evidence regarding their long-term reliability. ** If
they prove less durable than CFC refrigerators, the cost of additional repairs
and premature replacements could be significant. This potential cost is not included
in thetotal accounting.
TTiere are about
150 million
refrigerators in
domestic use in
the U.S.
HFC-I34a
refrigerators are
unlikely to be as
reliable and long-
lasting as their
CFC-using coun-
terparts.
Lieherman: The High Coil of Cool
P»ge9
250
TTiere is no legal
requirement that
CFC equipment
be retired, only
that CFC produc-
tion cease.
Chillen
There are at least 80,000 chillers operating in the United States. " Chillers,
so called because they chill water which is used to cool air, are the most efficient
means to air-condition large buildings. They also provide the cooling in certain
industrial applications. About 65,000 arelow-pressurechiUers that useCFC-1 1,
and most of the rest are high-pressure chillers that operate with CFC- 1 2, HCFC-
22, or R-500 (a mixture that includes CFC- 12)." These systems are expensive
to purchase and install and are expected to last more than 20 years. Most contain
a thousand or more pounds of refrigerant, and often have high leak rates. ** Thus,
the future of this equipment has been significantly affeaed by the phaseout.
Thus far, less than 1 0 percent of chillers have been replaced or retrofited
to usenon-CFC refrigerants."* Most will still be reliant onCFCs when production
comes to an end in 1996.*'
Chiller owners are faced with several choices, and must make them in a
short period of time and with limited information. Basically, they can contiraje to
use CFCs, retrofit existing equipment to use an alternative refrigerant, or replace
their system with a totally new non-CFC chiller. Each choice entails significant
additional costs. Which option is appropriate in each case depends on the type
and condition of the chiller, and the characteristics of the building it is located ia
It also depends on the future availability of CFCs and the rate of non-CFC
technological breakthroughs. Atthispoint,thenumberofchillerownersthatwiU
chooseeachoptionarulthetotalcostcanoniybeestimated. ThethreeoptionswiU
be discussed in turn.
Continue Using CFCs:
There is no legal requirement that CFC equipment be retired, only that
CFC production cease. Existing CFC chillers can be used beyond the phaseout
date, provided that suflBcient refrigerant is available. However, with CFC
production to end in 1995, the only way of assuring the long-term operation of
CFC chillers is to minimize the amount of additional refiigerant needed. This
requires refiigerant containment, i.e. taking steps to reduce refrigerant leakage,
and recovering(ratherthan venting) refrigerant during maintenance and servicing
(bothofwhicharealso regulatory requirements). It also necessitates storing extra
CFCs forfliture use." ThisoptionisparticlarlyattractiveforCFC-l Ichillersin
good working order, whereleakagecanbereducedtoaminimum." Assuming
that about half (30,000 to 35,000) of the CFC-1 1 chiller owners choose this
option over the next decade, and the average cost is approximately S20,000 to
S30.000partsandlabor,**thetotalcostoverthenextdecadewiI]beS0.6toS1.05
billion dollars.
Retrofit:
For about 1 5 ,000 to 20,000 existing chillers, retrofitting to use alternative
refrigerants is an economically sound decision. Perhaps 10,000 to 15,000 CFC-
1 1 chiller owners, anxious to end theirreliance on CFCs. will choose to retrofit to
Page 10
Lieberman: The High Cost o/Cool
251
HCFC- 1 23 Retrofitting will also be chosen by the owners of many relatively new
CFC-12 and R-SOO chillers, because difficulties in reducing leakage makes
continued reliance on CFCs risky, and total replacement would be wasteful. They
can be retrofit to use HFC-n4a. In either case, a retrofit entails extensive
modifications to a chiller** Retrofit costs range from $10,000 to well over
S 1 00.000 ** Assuming an average retrofit cost of S50,000, the total cost of
retrofitting chillers will be S0.7S to $ 1 .00 billion over the next ten years.
Premature Replacement.
Since continued reliance on CFCs or retrofitting involves significant costs
and risks, some building owners may choose to purchase and install anew chiller."
Assuming 30,000 existing chillers will have been replaced in the next 1 0 years,"
and half of these replacements are anributable to old chillers in need of replacement
anyway, 15,000 replacementscanbeattributedtothephaseout. New chillers vary
in cost depending on size, and the cost ofmstallation depends on the features of
each building. Assuming an averagecost ofS 1 20,000, these chillers will add S 1 . 8
billion to the phaseout cost."
Primarily because of safety concerns surrounding some of the replacement
re&igerams, new building code requirements for buildings with chillers are likely to
become law."* The American Society of Heating, Refrigeration, and Air-
ConditioningEngineer5(ASHRA£) sets the model standardswhichnearlyali local
building codes follow.^' Standard 34 categorizes refirigerants based on their
toxicity and flammability. The most commonly used CFCs and HFC- 1 34a are
listed as A 1 , because they have low toxicity and low flammability. HCFC- 1 23 is
classified B 1 , because ofhigher toxicity and low flammability.^ Standard 1 S now
requires that equipment rooms with a class A 1 -using chiller have ventilation
systems, oxygen monitors, and a self-contained breathing apparatus. B 1 -using
chillers require a refrigerant vapor detector and alarm system in addition to these
requirements. The typical cost ofbringing abuilding into compliance will be fix)m
$ 1 0,000 to $20,000. " Assuming an averageofS 1 5,000, the cost for all 80,000
chillers will be $ 1 . 2 billion.
Total Costs:
Within the next two years, chiller ownen will have to make the transition
to a market where CFCs, if available, will be very expensive. The total cost of
continuingtheuseofCFCs, retrofitting, orreplacingchillers, as well asthe cost of
compliance with new safety standards will be $4.4 to $5.0 billion over the next
decade.
Commercial and Institutional Refrigeration
There are at least five million (and probably closer to ten million) pieces of
CFC -using commercial and institutional refiigeradon and freezing equipment in the
US." They are used in the 24,000 supermarkets and 228,000 smaller food
TTtere are safety
concerns sur-
rounding some of
the replacement
refrigerants.
Uebermtm: The High Cost of Cool
Page It
252
A typical super-
market will cost
approximately
$45,000 to retro-
fit.
stores," 729,000 restaurants, bars, hotels, schools, and other places that serve
food and drink,'* and approximately 200,000 other businesses (pharmacies
liquor stores, florists etc.) that require such equipment." Complying with the law
will be a complex and expensive task.
These applications require equipment that provides a large volume of
storage space for refrigerated or frozen items. Like chillers, these systems are
expected to last a long time and occasionally leak, requiring additional CFC
supplies to stay operational. Therefore, over the next decade, most of them
will be retrofit to run with alternative refrigerants." As with chiller owners,
the majority of aflfeaed establishments have not yet done anything, thus the
total costs can only be estimated at this time. It is assumed that these costs
will eventually be passed on to consumers.
Supermarkets and Food Stores:
Retail refrigeration equipment falls into two general categories, medium
and low temperature. Medium temperature equipment includes meat, fish, dairy,
delicatessen, and produce cases, and walk-in coolers for storage. Most medium
temperature systems use CFC- 12. Low temperature applications include multi-
deck fi-ozen food cases, closed door freezer cases, and open chest type freezers
and walk-in freezers. Most of this equipment uses a mixture called R-S02, which
contains CFCs. Supermarkets typically have about 30 medium and low tempera-
ture systemi while convenience stores and other small food retailers have fewer
than 1 0, and the systems tend to be smaller than their supermarket counterparts.
The cost of retrofitting a singlesystem in a supermarket is approximately
51,500." Thus, a typical 30-system supermarket will cost approximately
S4S,000 to retrofit. ThisamountstoSl. I billion nationwide. Smallerfood stores
will probably range from $3,000 to $5,000 each, or $0.7 to $1.1 billion
nationwide.
Food Service:
The 729,000 restaurants and other places that serve food or drinks
typically have 1 0 or fewer pieces of equipment. In addition to having the same
types of equipment used in food stores, they will also have ice machines and
small, self-contained equipment for storing and serving food and drinks."
Typical retrofit costs are estimated to be in the $1,000 to $3,000 range, for
a total of $0.7 to $2.2 billion.
OtherCommercial Uses:
At least 200,000 other businesses use refrigeration, usually fewer than
fivepieces of self-contained equipment. The retrofit cost to these businesses will
probably average of $250 to $500 each, or $0.5 to $ 1 .0 billion in total.
Page 12
Utbermcm: The High Con o/Cool
253
Total Costs:
Well over one million establishments will have to make changes in their
refrigeration equipment in order to cope with the lack CFCs The total cost
for these businesses and institutions will likely be $3 0-$5 4 billion.
HCFC Equipment
In addition to CFCs, a related class of refrigerants called
hydrochlorofluorocarbons (HCFCs) are also being phased out of produaion,
but under a slower timetable. In the U. S . , HCFC-22, the most commonly used
HCFC. will be phased out beginning in 2010 " However, it is possible that
the deadline will be accelerated.
HCFC-22 is used in 43 million central air-conditioners in America's
homes, and in about 2 million air-conditioners in other buildings." The
refrigerant recovery rules also apply to HCFC-22 equipment. On average,
central air-conditioners require the type of servicing necessitating recovery
once every five years. Thus, in a given year, approximately 20 percent of the
nation's central air systems will require refrigerant recovery. Assuming nine
million of these procedures are performed on residential and other central air-
conditioners annually at a typical charge of $40 to $60,** the total cost will
be S360 to SS40 million annually, or S3. 6 to SS.4 billion over the next decade.
Further, air-conditioners use about half of the 300 million pounds of HCFC-
22 produced each year." Thepriceof HCFC-22 has doubled from aboutSl per
pound to S2.'' AssumingthepriceremainsatS2 per pound, an additional SISO
million will be spent annually on HCFC-22 for air-conditioning, or S 1 . S billion over
the next decade. Added to the refrigerant recovery costs, the increased costs
associated with HCFCs will total $5 1 to $6.9 billion for the next ten years.
In addition to central air-conditioners. HCFCs are used in some chillers,
commercial refrigeration units, and other equipment. Also, a number of CFC
systems are being retrofit to use HCFCs. A future supply ofHCFCs will be needed
to maintain these systems. If the HCFC phaseout is accelerated, as some predict,
the additional cost of compliance would be great.
Other Equipmentand Uses
In addition, other types of CFC-using air-conditioning and refrigeration
equipment will also be affected, but are not separately discussed. Refrigerated
transports (trucks, rail cars, ships, sea-land containers), refirigeration used in
industrial processes, medical and laboratory equipment, dehumidifiers, water
coolers and drinking fountains, and vending machines are not included. In
aggregate, the cost of replacing or retrofitting these systems will be significant, but
are left out of the total accounting for this paper.
Hydrochlorofluoro-
carbons (HCFCs)
are also being
phased out of
production
Lieberman: The High Cost of Coot
254
Finally, it must also be remembered that CFCs are also used for other
applications besides refrigeration and air-conditioning. CTCs have been used as
cleaning agents, solvents, and as blowing agents for foam insulation. The
accompanying chart displays the distribution of CFC uses in the United States
priorto the signing ofthe Montreal
Protocol. Note that before the
phaseout, refrigeration accounted for
less than half of total CFC use in the
United States.
DISTRIBUTION OF CFC USES
PRIOR TO MONTREAL PROTOCOL
SOCKCE AlliaiKC fort RespomiMcCFC Polky
CONCLUSION
The total costs of the CFC
phaseout on refrigeration and air-
conditioning will be an estimated
$44.5 to $99 4 billion overthe next
decade (see table on page three)."
These costs will ultimately be borne
by consumers, and will average $445
to $994 per household. This in-
cludes direa cost increasesof own-
ing and maintaining a vehicle air-
conditioner, an air-conditioned residence, and a refrigerator, as well as indirect
cost increases affecting such things as food and rents in commercial buildings.
However, this estimate does not include a wide-range of other costs that will be
felt by consumers, including decreased convenience and efficiency.
Moreover, the phaseout has forced the reallocation of corporate research
and development monies The demand to meet the phaseout's requirements in
time has meant that other, potentially more lucrative, investments have been
deferred. These foregone opportunities are difficut, if not impossible, to measure,
but represent additional costs imposed by the phaseout
The CFC phaseout will likely become the single most expensive environ-
mental measure taken to date. During the policy debate, the costs were
underemphasized to the point that they never became an important factor. The
impaa on consumers was scarcely considered. However, as consumers begin to
pay for this policy they will recognize that environmental measures can be
expensive undertakings. It may be too late to reverse course on the CFC
phaseout, but it can serve as a lesson for the future.
Page 14
Leberman: The High Cost o/Cooi
255
ABOUT THE AUTHOR
Ben Lieberman is an environmental research associate at the Competitive
Enterprise Institute. He is author of "Stratospheric Ozone Depletion and the
Montreal Protocol: A Critical Analysis" in Buffalo Envitotunental Law
Journal, Spring 1994 Mr Lieberman holds a J D. from the George Wash-
ington University National Law Center.
Ufhtnmm: Tht High Cosi of Cool Pige 15
256
ENDNOTES
' SeeM J Molina andF. S Rowland. "Stratospheric sink for chJorofluoromethanes: chlorine atom-catalysed
destruction of ozone," Mi/we 249(1974): 810-812; ExecutiveSunmaryoftheOzone Trends Panel, March 15,
1988, Synthesis of the Reports of the Ozone Scientific Assessment Panel, Environmental Effects Assessment Panel,
Technology and Economic Assessment Panel, Prepared by the Assessment Chairs for the Parties to the Montreal
Protocol, (November 1991).
'Ibid.
> For example, during the Senate debate on the acceleration ofthephaseout date from 2000 to 1995, many Senators
repeated claims of increases in skin cancer, cataraas, immune system suppression, as well as crop failures and
destruction of the ocean food chain that are said to be occurring as a result of an increase in ground level ultraviolet
radiation caused by ozone depletion. However, direct measurements of ultraviolet radiation show no such iiKrease.
In effect, the feared consequence of ozone depletion, a significant global increase in ultraviolet radiation, is not known
to be occurring Thus, the claims ofhuman health and environmental consequences are purely speculative. At the
same time, none of the Senators seriously discussed the costs of eliminating CFCs. See Congressional Record,
(February 6, 1992), SI 128 - SI 138.
* See ICF Incorporated, Reguiatory Impact Analysis: Compliance With Section 604 of the Clean Air Act for
the Phaseout of Ozone DepletingChemicals, (July 1 , 1 992), and addendum. (The costs of eliminating CFCs are
calculated a S9 billion through the year 2000, and the benefits, largely the millions of additional cases of skin cancer
assumed to be averted by the phaseout, are calculated to exceed costs by as much as S3 1 trillion).
' In addition to their role as refrigerants, CFCs, HCFCs and related compounds slated for phaseout have literally
hundreds of uses in agriculture, manufacturing, medicine, insulation, and fire suppression. In a number of these
applications, alternative compounds are either more expensive or less effeaive than the compounds they are
replacing. A detailed discussion of these costs is beyond the scope of this study.
' With limited exceptions, the law restricts CFC production and consumption (production plus imports minus
exports) regardless of the end use. Specific restrictions on each end use could have afforded the opportunity to tailor
the law to quickly proscribe CFC use in applications where CFC replacements are effective and economical (such
as solvents and cleaning agents), while allowing more time in applications where rapid CFC elimination poses a
substantial hardshi p (as in several refrigeration and air-conditioning uses). However, an across the board phaseout
was chosen, partly for political reasons. See Dan McInnis,"Ozone Layers and Oligopoly Profits." in Greve and
Smith, eds^Environmental Politics: Public Costs, Private Rewards, (New York: Praeger, 1992), p 145,
' Essential uses are narrowly defined to include uses that are necessary for health and safety reasons or are critical
to the functioning of society. In addition, it must be shown that there are no available substitutes that are acceptable.
' NASA News, Scientists Say Arctic "Ozone Hole" Increasingly Likely (February 3, 1992).
* Congressional Record, (Febtuaty 6, 1992), S1128-S1138.
'" NASA News, NASA Spacecraft Finds Large Arctic Ozone Depletion Averted (April 30, 1 992).
" 58 Federal Register 650li - 65082.
'^ DuPont, the largest CFC producer, had voluntarily agreed to cease production one year eariier than required.
However, the EPA, fearing shortages, persuaded them to continue production until thephaseout deadline.
Page 16 Leberman: The High Cost of Cool
257
" 58 Federal Register 65025 - 65028.
" Clean Air Act Amendments of 1 990. Sections 608 and 609; 58 Federal Register 28660 - 28734.
" Congressional Research Service, "CFC Phaseout: Future Problem for AirConditioning Equipment''" ( Aprill ,
1993). p 4.
'•Ibid.
' ' Had the phaseout been slower, industry could have settled on the best replacement refiigerant for each application.
Such standardization would have reduced the costs and complexitiesof moving away from CFCs. But with so little
ti me to act, and the replacement technologies still in the early stages, a large number of competing refrigerants have
been introduced into the market, many of which will become obsolete in the next few years, as the best refrigerants
emerge from the pack. The same is true for the many oils, filter driers and other components now on the market.
" For example, choosing the correct filter drier for an air-conditioning or refrigeration systemused tobe an easy task.
Now, with numerous combinations of refrigerants, oils, and additives, it isdi£5cult to know which type of filter drier
will perform satisfactorily. The incorrect choice can cause damage to a system by filing to properly remove enough
moisture, or by filtering out oil additives.
"Clean Air Act Amendments of 1990, Sections 608 and 609; 58 Federal Register 28660 - 28734.
" See "The Alternative Solution," Refrigeration Service Contracting, (November 1993), pp. 20-26.
" Informal survey ofthreewholesalersintheWashington,D.C area, March. 1994; Omnibus Budget Reconciliation
Actofl989, and subsequent revisions. (The tax is $4 3 5 per pound in 1994, rising to $5. 3 5 in 1995.)
" "Refrigerant Shortfall Challenges Chiller Owners," Air Conditioning, Heating and Refrigeration News
(March 22, 1993), pp. 2-3.
" Congressional Research Service, "CFC Phaseout: Future Problem for Air Conditioning Equipment?"
(April 1. 1993), pp. 9-11.
-•' Imported CFC- 12 Bypasses Tax, Sells For Less, Say Producers." Air-Conditioning, Heating and
Refrigeration Ne^vs (Ma.y 16. 1994), pp 1-2.
" For example, in automobile air-conditioners, some or all of the refrigerant has already leaked out before a
vehicle is brought in for servicing, and little or none is lef^ to be recovered. In cases of repairs of hermetic
compressor motor burnouts, the refrigerant may be too contaminated to be reused. Also, if two or more
recovered refrigerants are commingled, the entire mixture may be unusable.
•* See "Recovery-Recycling Unit Sales Still Soft", Air Conditioning. Healing and Refrigeration News (My
19, 1993), pp. 20-22; "ACCA Members Cite Poor Quality, Lack of Good 'Used' Refirigerant", Air
Conditioning. HeatingandRefrigeraiionNewsiSeptembeT6, 1993); "Recovered Refrigerant: Where is it?"
Air Conditioning. Heating atid Refrigeration News {May 16. 1994). pp 3-4.
2'McInnis.p. 148
" Informal survey of thre^ wholesalers in the Washington, D.C. area, March 1 994.
Uebtrman: The High Cost of Cool ''■8* ' '
258
"ChemicaJ Manufacturers Association, Production. Sales, and Calculated Release ofCFC-llandCFC-l2
Through 1988, Mclnnis, p 138, 1993 Statistical Panorama, /!//■ Co«J///onwg, Heating and Refrigeratior
News, (March 29, 1993), at 24.
""CFCs: The Challenge ofDoing Without", Electric Power Research Institute Journal, vol. 14. no 6(1989),
p6
" James M Calm, Charactersitc Efficiencies and Costs For Air-Conditioning Equipment With Selected
Refrigerant Altematives{y\r^wii:. Air-Conditioning and Refrigeration Institute, 1991 ).
" For example, air-cooled condensers on some retrofitted CFC-12 and R-502 condensing units are slightly
undersized, and during periods of hot weather will lead to higher discharge pressures and greater energy use.
Also, systems using non-CFC refrigerant blends require a fairly critical charge of refrigerant to maintain peak
efficiency. Thus, even a small leak will significantly increase energy consumption, as compared to CFC
systems where leakage had a smaller impaa on efficiency. Further, refrigerant cross-contamination may reduce
energy eflSciency, particularly in commercial refrigeration systems.
w'CFCs: The Challenge ofDoing Without," Electric Power Research Institute Journal, vol. 14, no. 6(1989),
p. 10.
" EPA, Moving to Alternative Refrigerants, November 1993; Alternative Fluorocarbons Environmental
Acceptability Study and the US. Department of Energy, Energy and Global Warming Impacts of CFC
Alternative Technologies (December 1991).
"Ibid.
•* American Automobile Manufacturers Association of the United States, Motor Vehicle Facts and Figures,
annual; Montreal Protocol, Report of the Refrigeration, Air-Conditioning and Heat Pumps Technical Options
Committee, (December 1991), Figure 10.1; 1993 Statistical Panorama, Air Conditioning, Heating and
Refrigeration News (March 29, 1 993), p. 7.
" Ward Atkinson, Sun Test Engineering.
'» Clean Air Act Amendments of 1 990, Section 609.
"Ibid.
"Atkinson
" 1993 Mobile Air-Conditioning Society. /wVi<E/5tfrvic«fZ)afti^oo/(;.
« Ibid.
" Many vehicle air-conditioning systems develop slow leaks, which cause the gradual loss of refrigerant Leakage
frequently occurs through high and low side Schrader valves, by difiusion through aging and hardened hoses, and
through the compressor shait seal. These minor leaks rarely damage the system, provided the pressure in the system
remains above atmospheric, and merely necessitate the addition of a pound or two of refrigerant. However, now
that a CFC recharge costs more, and future supplies are uncertain, some people may choose to have the leak
repaired, although such a Job will probably cost S2S0 or more. Many servicemen, for obvious reasons, are
encouraging customers to repair leaks rather than top off a system. Others, as a matter of policy, refuse to top oflF
Page 18 Liebtrman: The High Cost of Cool
259
systemsunless leaks are repaired. Some are telling customers that federal law requires leak repairs, which is not
the case
** Montreal Protocol, Report of the Refrigeration, Air-Conditioning and Heat Pum ps Technical Options Committee,
(December 1 99 1 ). p 1 73 (Some 1 992 and 1 993 CFC air-conditioners were designed to be easily retrofit to HFC-
1 34a, and the cost will be lower For older cars, depending on the model and year, the retrofit costs range fr^om $250
to $800)
" HFC- 1 3 4a and the poly alky lene glycol (PAG) oil used with it cannot operate properly in a system which previously
used CFC- 1 2 and mineral oil unless virtually all ofthe original refrigerant and lubricant is removed from the system.
Mineral oil is not miscible with HFC- 1 34a and any any left behind will reduce heat transfer and interfere with fluid
flow Residual CFC- 1 2 will combine with HFC- 1 34a to form an azeotrope, generating higher internal pressures.
It can be expected that some retrofits will fail because the system was not thoroughly flushed. Further, HFC- 1 34a
operates at a much higher discharge pressure, which will place a life-shonening strain on the system, particularly when
stalled in traffic on hot days.
** The low end of this range assumes that future servicing costs will be only slightly higher than current costs, while
the high end assumes significant cost increases, particularly after 1 99S .
'^Putnam, Hayes & Banlett, Inc., Report for the U.S. Department of Energy, Assessment ofthe Impacts
Associated with a Total CFC Phaseout (My 10, 1989), p. 11.
" The higher discharge pressures ofHFC- 1 34a will likely cause an increase in compressor failures. See "Race
Against Time", Design News (October I, 1990). pp. 132-136. Further, the polyalkylene glycol (PAG) oil
used as a lubricant is extremely hygroscopic (water attracting). See Tecumseh Products Company. Guidelines
For Utilization of R 134a. Thus, ambient moisture may be drawn into a system during servicing or after a
collision or other major leak, which can lead to system failure. Also, HFC- 1 34a, unlike CFC- 12, does not form
wear-reducing metal chlorides See ARI Tech Update, Lubrication is The Key Issue in CFCPhaseout (August
1 993 ) And. as with all new technologies that have not been thoroughly tested, there will likely be unforseen
problems that develop after a few years of actual use.
'* Several automotive engineers with major auto makers privately admit that they expect an increase in the
number of vehicle air-conditioners needing a major repair to stay in operation, particularly after about five
years of use.
"Congressional Research Service, CFCPhaseout: Future ProblemforAir Conditioning Equipment? (April
1, 1993). p5
" The fact that HFC- 1 34a is the most widely used replacement refrigerant, despite its many drawbacks, is a
consequence ofthe acceleration ofthe phaseout date from the year 2000 to the end of 1 995 Given the lead times
needed by manu&cturers, many industries had to make hasty decisions as to which replacement to use. A number
of other refrigerants are more promising than HFC- 1 34a but need a few more years of research and development
before being ready for use. On the other hand, HFC- 1 34a was one ofthe first replacements developed and mass
produced and was chosen largely because it was the best refrigerant available on such short notice. And, once an
industry commits to a particular refrigerant, it is very expensive to switch to another. As a result, HFC- 1 34a-will
likely see widespread use for many years, even in applications for which it is not ideally suited.
""AGreenerWay to Keep FoodCool," Washington Po^t. Home Section(April 14, 1994), p. 5; lleftigerators
For A Wiser Worid". Consumer Reports (February 1994), pp. 80-86.
Uthtrman: The High Cost of Cool •*•«* ' '
260
""1994 Statistical Panorama," Air Conditioning. Heating and Refrigeration News {\^n\ 1 1, 1994), p 32
« Montreal Protocol, Report of the Refrigeration. Air Conditioning and Heat Pumps Technical Option''
Committee (Dtctmbtr 1991), p. 80. HFC- 134a is primarily a medium temperature refrigerant, and is not wci.
suited for American refrigerators with a large freezer section, which operate at a coil temperature of about - 1 0* F
At this low temperature, HFC- 134a may exhibit reduced capacity versus CFC-12. See Dupont, Retrofit
Guidelinesfor Sifl'A li-ta in Stationary Equipment Some comparisons obfuscate the relative efficiencies by
comparing an advanced design HFC- 1 34a model with a basic CFC- 1 2 model, or by using theoretical rather than
actual efficiencies See EP\, Multiple Pathways to Super-Efficient Refrigerators Note that there may also be
aslight decline in efficiency resulting from CFC-blown foam insulation used in refrigerator walls and doors being
replaced by substitute foams.
" The polyol ester (FOE) oil chosen to be used in HFC- 134a refrigerators is 1 00 times more hygroscopic than the
mineral oil used with CFC- 1 2. IC for example, the system experiences a leak during mo ving or is left open for more
than 1 S minutes during servicing, enough moisture can enter to cause chemical reaaions that may damage the
compressor or block the capillary tubes, the latter requiring replacement of the entire hermetic system. In addition
to moisture problems, HFC- 1 34a and POE oils have a low tolerance for other contaminants, (such as residual
chlorine in servicing equipment that was also used to repair aCFC system). As a result, HFC- 1 34a refrigerators
will suffer more frequent breakdowns, some of which cannot be repaired. See Whiripool Corp., HFC-I34a
Refrigerant Service Procedures.
'* The experience with CFC- 1 2 refrigerators when they were new may be repeated with the new HFC-1 34a units.
The first models worked well initially, but suffered unexpected problems after several years of use. For example,
the oil originally chosen broke down, causing capillary tube blockage, and a new oil with additives had to be
developed. Also, theinsulationprotectingthemotorwindingswasweakenedbyunexpectedreactionsbetweenthe
refrigerant, oil, and trace impurities, and had to be replaced with a new type ofinsulating material. These and othe
technical problems were totally unanticipated when the systems were initially designed and tested. They revealed
themselves only after years of field experience. The same is likely to occur with the new HFC- 1 34a systems.
" 1993 Survey, Air-Conditioning and Refrigeration Institute.
'•"1993 Statistical Panorama," Air Conditioning. HeatingandRefrigerationNews,Maxz\\29, 1993, pp. 6-7
'* Alternative Fluorocarbons Environmental Acceptability Study and the US Department ofEnergy, Energy and
Global Warming Impacts of CFC Alternative Technologies (December, 1991)ch.6and App. E.
""SlowConversiontoNon-CFCsWorriesChillerManufacturers," AirConditioning. HeatingandRefiigera-
tion News (April 12, 1993), p. 3.
" Ibid.
" S pecifically, refrigerant containment first requires a thorough inspection of the system for leaks, and replacement
of any gaskets or connections that show signs of deterioration. Then, a high efficiency purge unit is installed, which
allows the system to be periodically purged of air without refrigerant also escaping. Isolation valves are installed at
the oil sump to reduce refrigerant leakage during oil changes. Pressurizing devices, which reduce leakage when the
chiller is not in use, and safety relief valves which prevent total loss of charge in an emergency may also be necessary
Older chillers may require eddy current testing of the condenser tubes in order to detect any weaknesses in them
CFC monitoring devices may be installed to aid in early leak deteaion. Since some leakage will still occur, an extra
supply of refrigerant needs to be obtained, and placed in a tank or drum suitable for long term storage. Refrigerant
recovery devices will also be necessary for use during servicing.
Page 20 Lelnrman: The High Cost of Cool
261
"CFC-I I chillers operate at sub-atmospheric pressures, thus not much refrigerant leaks out On the other hand,
CFC- 1 2, CFC-22 and R-500 operate at pressures above atmospheric, and a line break, for example, could cause
the entire refrigerant charge to escape.
** Informal survey of three chiller cbnfrattors, March 1 994 (Actual cost is dependent on the size, age, and condition
ofthe chiller and building.)
** A retrofit of a high-pressure chiller involves modifications ofthe geardrive and impeller (in order to reduce the
loss in capacity), and careful system flushing ofthe old refrigerant and oil. Finally, a charge ofHFC- 1 34a and
compatible ester-based lubricant is added. Low-pressure chiller retrofits to HCFC- 123 require modifications of
the motor and impeller, as well as replacement of motor windings, 0-rings, gaskets, and seals In both cases,
refrigerant recovery equipment will have to be procured.
•* Retrofit costs average $50 - $70 per ton, and chillers that are candidates for retrofit are in the 200 - 3000 ton
range. The term ton refers to the amount of cooling required to freeze one ton of water in aday, or 1 2,000 Btu/hour,
and isthe common unit for measuring cooling capacity. SeeEPA,A/ov;/»y to Alternative Refrigerants, TenCase
Histories, (November 1993); "OneCompany's Strategy", Engineered Systems, (September 1993).
*' Chiller owners who continue to use CFCs run the risk of needing additional CFCs at some fiiture date and not
beingable to obtain it. Also, retrofits to HCFC- 1 23 and HFC- 1 34, consideringthe initial cost, expected useful life,
and operating costs, may not be as attractive as a total replacement in some cases. In addition to new systems using
HCFC- 1 23 or HFC 134a, HCFC-22 chillers using screw compressors are gaining market share because of their
efficiency and versatility.
" An Air-Conditioningand Refiigeratkin Institute survey of chillermanu&cturers estimates that 22,0OOCFC cMllera
will have been replaced by non-CFC chillers by the year 1 996.
""One Company 's Strategy," Engineered Sysiem% ( September 1 993 ). (Estimated cost of chiller replacement
is $275 -$375 per ton.)
" Strictly speaking, these new requirements are not a direct consequence ofthe CFC phaseout, and in fact are
applicabletochillersthatuseCFCs. However, theirpromulgationoccurredasaresult of concemsoverthetoxicity
of replacement refrigerants, particularly HCFC- 1 23 .
"See "Taking The FearFactorOutofRefngerants." £n^/wer«>(/5v5leOTj(January 1994), pp. 42-47 (Most local
building codes have not yet made these revisions, but are expected to make them v^thin the next two years. )
"Ibid
" Informal survey of three chiller contractors, March, 1 994.
" Sutement ofthe Air-Conditioning and Refrigeration Institute on Depletion ofthe Stratospheric Ozone Layer.
January25, 1990. (Thisisaveryroughestimate, and islikdy too low, given thenumberofestablishmentsusingsuch
equipment. Other estimates are lower, but exclude many categories of equipment. )
" Statistical Abstract ofthe UnitedStates 1993, "Retail Foodstores-Number and Sales, by Type: 1980 to 199 1,"
p. 777.
^* Statistical Abstraflqf the UnitedStates, "Commercial and Institutional Groups-Food and Drink Sales: 1980
to 1 993," p. 779.
LubenHtm. The High Com o/Cool Page 21
262
" Statistical Abstract of the United States, "Retail Trade Establishments-Number, Sales, Payroll, and
Employees, by Kind ofBusiness: 1 987," p. 775.
" Some ofthis equipment, particulariy the smaller systems, will practice containment and continue using CFCs for
as long as supplies are available. Nonetheless, it is assumed that most existing systems will be retrofit within the next
ten years.
" "Allied Signal's AZ-SO Alternate Refrigerant Well-Received By Texas Supermarket Chain", AirConditioning.
Heating and Refrigeration News (January 24, 1994), p 76. A retrofit of a commercial refiigeration system
involves removing the original CFC charge, replacing the filter drier, recharging the system with a new refiigerant and
compatible oil (medium temperature refiigerant replacements include MP-3 3 , MP-3 9, MP-66, and HFC- 1 34a,
while low temperature replacements include AZ-50, HP-62, HP-80, HP-8 1 , HFC- 1 25, and HCFC-22), and a
check of the system for proper performance. A supermarket will require about 300 hours of labor, while a
convenience store may require 30 hours or less.
** Thus far, very few self-contained systems have been retrofit It is expected that their owners will continue to use
CFCs until they are no longer available, and then retrofit or replace the equipment. Retrofit costs will probably be
in the $200-5300 range.
"58 Federal Register 60 1 5 8 . (Another HCFC, HCFC- 1 23 , is being used in many new and retrofit chillers, and
is discussed in that section. Its production will be fi'ozen in 20 1 S and eliminated in 2030. )
" US Bureau of the Census, Current Housing Reports; Energy Information Administration, Commercial
BuildingCharacteristics: 1 989, Table 86. (There are also about 50 million window air-conditioners, which are not
significantly impacted by the phaseout. Large buildings are cooled by chillers, and are discussed separately.)
" Informal survey of 5 residential air-conditioning servicemen in the Washington, DC. area, March 1 994.
•*" 1994 Statistical Panorama." Air-Conditioning, Heating and Refrigeration News (April 11, 1994),pp.25-
26.
" Informalsurveyofthree wholesalers in the Washington, DC. area, March 1994 (The other half ofHCFC-22
production is used chillers and commercial equipment and is discussed separately.)
^ Had the phaseout not been accelerated fi-om 2000 to 1 995, the cost would have been about one quarter of this
amount
Page 22 Utbtrman: Thi High Cost of Cool
263
STATEMENT OF PROFESSOR RICHARD L. STROUP, SENIOR AS-
SOCIATE, POUCY ECONOMY RESEARCH CENTER, BOZEMAN,
MT
Dr. Stroup. Thank you. I am an economist. My experience as di-
rector of the Office of Policy Analysis of the Department of the In-
terior for a few years in the early 1980s gives me some background
here to make some observations.
My job there, the job of the office I directed, was to give man-
agers, decision-makers — ^the secretary, the assistant secretaries —
the other side of the story.
The Secretary and the Assistant Secretaries recognize that every
agency, whether it's a pro-development agency like the Bureau of
Mines or a preservationist agency like the U.S. Fish and Wildlife
Service, or a scientific agency, like the U.S. Geological Survey, all
agencies tend to cite facts, to cite data and to interpret data so as
to enhance their budgets and so as to support the policy stands
that they've already taken.
I believe that the question before Congress is the following — is
the evidence on CFC impacts on the ground sufficient to force some
serious risks and some large costs onto the American public?
To promote public health and to promote other environmental
goals, we do w£int to avoid risks. And I believe that all policy
choices available here, every one of them, involves risks.
But also, we want to promote the development of citizen wealth
and incomes because wealthier is healthier.
I believe the accelerated ban harms this particular goal.
The key question then is: Will the known costs and the added
risks that we force onto Americans by banning CFCs rapidly, will
those problems be counter-balanced, offset by the benefits of re-
duced stratospheric ozone depletion?
Ben Lieberman has detailed some, or he details in his written
testimony some of the dollar costs. I might add that, as an econo-
mist, it's pretty clearly obvious that you cannot lower the dollar
cost to consumers by restricting their options.
You cannot make it better for the dollar costs of consumers by
taking away options from them.
I want to show the basis for expecting risks, serious health risks,
from the ban of CFCs, or the ban of any other widely-used chemical
or material.
I'll use the bans on asbestos use and the de facto bans on asbes-
tos resulting from some very pessimistic interpretation of asbestos
health risks relative to the assumed gEiins from using substitutes.
And I want to cite a few sentences here from a case that was be-
fore the 5th Circuit Court of Appeals. I want to cite a few sentences
from the three-judge panel's opinion.
The case is Corrosion-Proof Fittings v. EPA, 1991.
The three judges in their opinion said the following:
"We are concerned with the EPA's evaluation of substitutes, even
in those instances in which the record shows that they are avail-
able. The EPA explicitly rejects considering the harm that may
flow from the increased use of products designed to substitute for
asbestos, even when the probable substitutes are known carcino-
gens."
And then they go.
264
"Many of the substitutes that EPA itself concedes will be used
in place of asbestos have known carcinogenic effects."
And they go on.
"Eager to douse the dangers of asbestos, the agency inadvert-
ently actually may increase the risk of injuries Americans face."
The court then references, "EPA's explicit failure to consider the
toxicity of likely substitutes."
One final sentence from the court here.
"In short, a death is a death, whether occasioned by asbestos or
by a toxic substitute product."
I want to move now to another result, not a toxic result, but an-
other result of the overemphasis of one risk relative to others. And
that is, as some in this room know, the extremely pessimistic inter-
pretation of asbestos science by advocates also led to the horribly
tragic results of the Challenger tragedy.
The maker of the asbestos-containing putty used to seal the O-
rings of the Challenger stopped producing the putty because of the
public asbestos scare and the fear of asbestos lawsuits, which were
burgeoning at that time. They stopped producing the stuff.
So a new putty had to be used.
The new arrangement failed. The seven astronauts died a fiery
death, traumatizing millions of us who saw the tragedy.
There are arguments about whether NASA should have seen the
problem and acted differently. But no one to my knowledge argues
that the old 0-ring system with the original putty would have
failed.
I don't know of anyone that makes that argument, that it would
have failed anyway.
That 0-ring system, that old 0-ring system that was no longer
available, like CFCs today, had a proven track record of safety and
effectiveness.
I believe that Ben Lieberman is right, that the monetary costs
of quickly phasing out CFCs are large. Many alternatives have to
be tested to discover which is the best for every application.
When that has to be done quickly, it won't be done as thoroughly.
Like asbestos, CFCs can certainly be replaced. But not without
sacrificing many benefits, such as safe, cheap refrigeration, which
increases food safety and has other advantages as well.
As Dr. Robert Watson of NASA, who we heard from earlier this
morning, has put it, and I quote here. He was quoted in 1988: "If
we banned all CFCs tomorrow, probably more people would die
from food poisoning than would die from ozone depletion."
Fortunately, we did not ban it tomorrow. There have been tech-
nological improvements since Dr. Watson said that. But a key
trade-off remains — more costly equipment will be used more spar-
ingly. Refrigerators will be smaller and fewer than they otherwise
would have been had the CFCs and the technological change over
time, too, been made available.
By contrast, refrigerators that are less costly and require less en-
ergy when they're used with equally advanced equipment using
CFC substitutes, would allow more and larger refrigerators, provid-
ing safer foods, causing less food poisoning, and in fact, less cancer
as well.
265
Time is an important element in advancing technology. Reducing
the time available before the substitutes have to be found and per-
fected and made available to ordinary people is surely increasing
the cost of the substitutes.
Mr. ROHRABACHER. Time is also important in the hearing, Mr.
Stroup. [Laughter.]
Dr. Stroup. Okay.
Mr. ROHRABACHER. If you would like to give a 30-second sum-
mary, go right ahead.
Dr. Stroup. All right. How much do we risk by reversing the ac-
celeration of the CFC ban in the U.S.?
I don't expect any agency or the head of any lab which is better
financed when the public and the Congress strongly have a concern
about this because that leads to better funding.
I don't expect any scientist in that position to say, it is not a
problem.
I, and virtually every scientist, will say, it is a problem. It's only
a question of how big a problem. I think the evidence is that, over-
all, our children will thank us if we reverse the acceleration of this
phase-out.
[The complete prepared statement of Professor Stroup follows:]
266
Prepared Testimony of Richard L. Strou^ 3
Before the Subcommittee oB^pergy_and-Jhe'Enviroiunent
of the House Committee on Science
September 22, 1995
Mr. Chairman and Committee members: I want to thanlc you for the opportunity to
provide my views on the economics of policies regarding the accelerated U.S. phaseout of
CFCs. I am an economist and have been applying economic analysis to environmental and
natural resource questions since my participation in the 1960s, as an economics doctoral
candidate, in the Air Resources Program at the University of Washington. My dissertation, on
the economics of controlling sulfur dioxide emissions, was written under the sponsorship of
that program. Since that time I have been researching, writing and teaching about
environmental and natural resource issues as an economics professor at Montana State
University and as a senior associate of the Political Economy Research Center. Under the
Intergovernmental Personnel Act, I also served for two and a half years as Director, Office of
Policy Analysis, at the U.S. Department of the Interior.
Cost of the Accelerated Phaseout of CFCs
A number of costs will be imposed by the accelerated phaseout of CFCs. Some of them
have been estimated. The phaseout is intended to provide benefits, of course, in the form ot
decreased depletion of stratospheric ozone. The existence of some benefit, in the form of
reduced destruction of stratospheric ozone seems clear, although the size and importance of
that benefit is very much in question by scientists and others, due to the uncertainty of the
impact of CFCs on the complicated chemistry of the ozone, and on the UVB reaching the
earth's surface. Large costs due to the phaseout seem unavoidable, although here again there
are serious questions about just how large they will be. Cost estimates of certain cost
components are available. The most comprehensive cost estimates are, I believe, those of Mr.
Ben Lieberman, who is with us today. However, these and other estimates must, of necessity,
be based on assumptions about technological innovations that are still being tested, and m
some cases innovations that are still being researched. These dollar figures cannot and do not
claim to give the fiill picture. In my remarks, I would like to share with you some
considerations that should be included in the analysis of how science is used in policies that
phaseout the manufacture and use of CFCs.
Proper decisionmaking requires fully and impartially examining both the gains claimed
for any policy option, and the sacrifices imposed by that policy. It is important to recognize
that those sacrifices will be real. Even when they are expressed as expenditures of dollars, the
dollar figures represent real sacrifices and real harms to people. Among these are health risks
imposed by the accelerated phaseout of CFCs.
Costs Are Not Just Monetary Costs
The monetary costs of quickly phasing out CFCs are large. Many alternatives must be
tested to discover which is best for each application. Currently, due to the accelerated
phaseout, different refrigerants are being used to replace CFCs in various uses. To avoid
mixing these substitutes, separate facilities must be built and maintained, and it is important
1
267
that refrigerants must not, for technical reasons, be accidently mixed. Yet mistakes are made
despite the expense of the separate facilities. If there were more time for detailed testing in
laboratories, these compounds would be more extensively tested before being used in the field,
so that fewer of them would be "field tested" to the extent that they are. As a result, fewer
problems would probably occur. This and other problems increase the likelihood that mistakes
will affect efficiency, cost and even the safety of those working with and near the refiigerants.
But there are other harms likely to be done as well. CFCs can be replaced, but we will
sacrifice their many benefits, such as safe, cheap refrigeration, which increases food safety
and has other advantages. The accelerated phaseout of CFCs is increasing cost and thus, for
many people, reducing availability. Dr. Robert T. Watson, of NASA, has put it, "If we
banned all CFCs tomorrow, probably more people would die from food poisoning than would
die from depleting ozone."' Of course some technological improvements have been made
since Dr. Watson said this, but the key tradeoff remains: more costly equipment will be used
more sparingly.
By contrast refrigerators that are less costly and require less energy than those with
equally advanced equipment using CFC substitutes, would allow more and larger refrigerators,
providing safer foods and causing less food poisoning and less cancer.^ While technological
advances in refiigeration equipment are continuing, as they would if CFC use were not being
phased out, we should not attribute most of the advances we see in refrigeration technology to
the CFC ban. Many would occur without the ban. To allow CFC use for a longer period
would almost surely make refrigeration cheaper than it will be with the accelerated phaseouL
Time is an important element in advancing technology; reducing the tinte available before
substitutes must be found and perfected is surely increasing the cost of those substitutes.
In contrast, allowing more time would reduce the costs of the changeovCT. Making
more time available would also decrease the likelihood of costly mistakes, safety hazards and
failures. The artificial speedup means that replacements and the equipment needed for them
are less fiilly researched before decisions must be made; and they are less fiilly tested before
they come into use. Our knowledge of their safety is unnecessarily limited under this policy.
The Presumed Benefits of Technology Forcing
It is often claimed that benefits from policies such as the rsq)id phaseout of CFCs wiU
bring important advantages by forcing industry into technological improvements. New
technologies to reduce the problems of chemically less stable replacements fnr the forbidden
CFCs will surdy appear, and they may even provide spinoff boiefits. But that is likely to be
true of any K&D expenditures; and if R&D projects could be chosen to address a wider array
of goals rather than being forced by law into mitigating the problems from rq>Iacing CFCs
very rapidly (and thus in a more costly fashion), we should expect greater total benefits. Only
if there woe severe costs brought on by the failure to accelerate the replacement, and thus
avoided by rapid replacement, would the shift of resources to the accelerated replacement be
likely to provide superior returns to the forced investment.
Potential Environmental Problems from Accelerated Phaseout of CFCs
New chemical products that will escape into the atmosphere, especially when they are
adopted r^idly, pose a potential threat to the environment. Replacements for CFCs are no
268
exception. T. K. Tromp and his colleagues, writing recently in Nature, the prestigious British
journal of science, pointed out the potential problem of three of the proposed replacement
compounds, theorizing that the breakdown products from those substitutes might become
concentrated in certain wetlands. The breakdown products, if concentrated, can harm certain
sensitive species. The concentration problem is theoretical rather than actual and measured at
this point, but then so is the problem of increased UVB reaching the surface of the earth due
to CFCs. Neither danger may in fact be serious, but the costs of replacing CFCs are much
more likely than the simply theoretical costs of not doing so. In addition, the danger from
reversing the acceleration, and phasing out the use of CFCs over, say, 4 additional years,
should be quite small.
Business Support for the Accelerated Phaseout of CFCs
Despite the meager health benefits that may be gained by accelerating the CFC
phaseout, and the ^parent high cost of the phaseout, which may include sonw theoretical
problems such as the concentration in nature of chemical breakdown products from
replacements, the acceleration policy will receive some prominent support. That support will
in part come from businesses that provide (or will try to provide) substitutes for CFCs. Such
businesses can be expected to support the rs^id phaseout of CFCs for the same reason that
suppliers to the military support larger budgets to procure the products they make, and
highway construction firms support larger highway constniction budgets. Supplien of CFC
substitutes, like suppliers to the military and to the highway program, want to increase the
demand for their products, and to increase it as soon as possible. They are investing in
providing the new products, and they will gain more profits if demand tot their products is
stimulated more, and earlier, by the accelerated phaseout.
Mistaking Costs for Benefits
Costs of programs such as the accelerated CFC phaseout are sometimes viewed,
falsely, as benefits to society. The argument made is that demand for new equipment due to
the policy will spur the economy, and that jobs are created by the need to scrq) functioning
refrigeration or air conditioning units, for example. But this is very much like viewing a
terrible hurricane as a generator of benefits because it creates a huge demand for rebuilding
what the hurricane has destroyed. Similarly, considering this production and these jobs as a
benefit of the program requiring that economical, working equipment be replaced, is simply
wrong. Any net benefits accruing to society firom replacing CFCs more quickly will come
from reducing the harmful effects of CFCs, not from the increased demand. Forcing users to
replace economical, functioning equipment with new equipment to meet the law is, in itself, a
cost to be borne, not a benefit.
Wealthier Is Healthier and More Environmentally Sound
Here, as in all of environmental policy, it is important to recognize the importance of
income and wealth, in providing our society with both the willingness and the ability to make
sacrifices for a better environment. Poorer people are usually willing to settle for lower
environmental quality, just as they must settle for lower quality food, housing and clothing. To
reduce ozone depletion from CFCs on an accelerated basis will impose sacrifices of income
269
and wealth, as these are usually measured.
Richer nations-those having experienced significant economic growth-are
environmentally cleaner and more healthful than are poor nations.' There are at least two
reasons for this: First, to become richer, societies develop technological tools that use
resources more efficiently and thus place less stress on the natural environment, per unit of
output. Second, people who have met their most basic needs and do not need to worry about
where the next meal will come from will demand a better environment and can afford it, just
as they demand better food, shelter and medical care. Results from one study suggest that
when community income rises by one percent, community demand for environmental quality
rises by three times that amount. In other words, the demand for environmental quality rises
with income at about the same rate as does the demand for BMWs!*
The correlation between income and environmental quality will not surprise anyone
who knows that the memben of environmental groups such as the Sierra Club have incomes
that, on average, are double those of the average American.' Any policy that reduces a
nation's income will reduce its willingness and ability to pay (in economists' lingo, its
demand) for environmental quality. Policies that promote economic growth will leskd to better
environmental quality.
Reasonable estimates of costs for the accelerated phaseout of CFCs run into the tens of
billions of dollars. The impact of this goes beyond the creature comforts and market goods
that we normally consider, and even beyond environmental goods and services: wealth and
efficiency are among the most important risk-reducing and health-enhancing factors in all
societies. Such a policy is good on balance for the environment only if it brings siihstantial
benefits to offset the resulting reduction in demand for other environmental programs.
It is important to recognize that economic growth does not £avor only those whose
personal incomes rise. That is, it isn't just individually affluent people who benefit from a
society's wealth and economic efficiency. Any person, whether rich or poOT, is much better
off to be caught in a disaster such as a flood or an earthquake in a rich country than in a poor
one. A rich nation can protect itself better against foreseen dangers and unforeseen
developments as well.^ To the extent that nations (and humans generally) have the advantages
that come from societal wealth, they have by far the best hope to avert ot survive crises from
threats of almost any imaginable risk, firom a large meteor on a collision course with Earth to
a new and niore virulent form of AIDS. Richer societies are more resilient. If 'insurance'
against a particular risk, such as some increase in the threat of increased UVB reaching the
earth, is bought at the cost of reduced economic growth, then a decline in the automatic
insurance represented by wealth, and the societal resilience it provides, is one of the costs
borne by future generations. It is a cost that might be worth bearing, but surely not without
careful consideration.
Inquiries like this hearing, into the application of science as applied to regulatory
policy, are conducted for good reason. The pressures and incentives facing political and
bureaucratic decisionmakers help to explain regulatory inefficiency. Efficiency, after all, has
no political constituency. Each important political group naturally seeks advantage for itself
and for its point of view firom the political system. The political system cannot operate
efficiently when doing so gets in the way of powerful interest groups or populist passions.
Unfortunately, an agency estimating the costs and benefits of its proposed regulations tend to
270
bias the results to support the policy of the agency. That is, any agency has what Justice
Stephen Breyer calls "tunnel vision.* It readily sees the benefits of what it has set out to do,
but seldom sees the full costs of that chosen course of actions when others can be made to
bear those costs.
The accelerated phaseout of CFCs is, in my view, a very costly policy. The tendency
to ignore or understate costs causes inappropriate optimism about the ease of replacing CFCs
on an accelerated basis. I am confident that our children will, in all likelihood, thank us if this
policy is reversed.
ENDNOTES
1. Watson was quoted by Alston Chase, in Chase's column in Outside magazine March,
1988.
2. In addition to reduced food poisoning, for example, cancer of the stomach was reduced by
the availability of home refrigeration, according to Howson, et al., in 'The Decline in
Gastric Cancer ^idemiology of an Unplanned Triumph,* in Epidemologic Reviews, Vol. 8,
(1986), p. 2.
3. See World Bank economist Marian Radetzke's, 'Economic Growth and Environment,*
presented at a World Bank Symposium November 21-22, 1991, for a review of the evidence
and reasons why the relationship between economic growth and environmental quality tends
to be positive.
4. These results were reported by Donald Coursey, economist at the University of Chicago,
in *The Demand for Environmental Quality,* a paper presented January 1993 at the annual
meeting of the American Economic Association in Anaheim, CA and in private conversations
since that time.
5. A 1986 survey of readers of the Sierra Club magazine indicated that the median household
income was $46,100, compared with median household income in the U.S. of $23,618. A
full 83% had graduated firom college, while among Americans as a whole, 19.4% had
completed four or more years of college in 1983. (Sierra Qub majgazine data provided by the
Sierra Club, 530 Bush St, San Francisco, CA 94108.)
6. Perhaps the best comprehensive treatment of this general topic was presented by the late
Aaron Wildavsky in Searching for Sitfety (New Brunswick: Transaction Press, 1988),
especially in Ch. 3.
271
Mr. ROHRABACHER. Thank you, Mr. Stroup.
I know it's very difficult for an economist.
Dr. Stroup. And a professor, too.
Mr. ROHRABACHER. And a professor, too. But I will refrain from
a joke about laying economists head to head, and I'll just refrain.
Dr. Stroup. Thank you, sir. [Laughter.]
Mr. ROHRABACHER. Dr. Pollet.
STATEMENT OF DR. DALE K. POLLET, PROJECT LEADER, EN-
TOMOLOGY, LOUISLVNA COOPERATIVE EXTENSION SERV-
ICE, BATON ROUGE, LA
Dr. Pollet. Mr. Chairman, Members of the Subcommittee, my
name is Dale Pollet and I am entomology project leader for the
Louisiana Cooperative Extension Service.
My full credentials are part of the written record submitted to
the Committee.
You have asked that I address the economic impacts of the
phase-out of methyl bromide. Attached to my written statement are
various references, well-accepted economic analyses. They consist-
ently show the loss of methyl bromide will severely impact Amer-
ican farming and food production.
American farmers depend on methyl bromide to grow, store,
transport, and process more than 100 vegetables, fruits, grains and
fiber.
Mr. Chairman, in your State of California, the phase-out will se-
verely harm the production of grapes, strawberries, carrots, wal-
nuts, pecans, cherries and other berries, rice, citrus, tomatoes, pep-
pers, plums and melons.
If the ban takes effect, California's fast-growing agricultural ex-
port business will come to a stop since Japan and other major mar-
kets require that imported produce must be fumigated with methyl
bromide.
The ports of Los Angeles, San Diego and Oakland will lose sub-
stantial revenues. Methyl bromide is also used in the ports of New
Orleans and Baton Rouge to fumigate cut flowers, grains, vegeta-
bles, propagative plant material, lumber, and lumber products.
Oakland's American Presidents Line reports that it alone would
lose $50 million in revenues annually. Introduction of a new de-
structive pest into California would cost farmers in that state $1.2
billion and would affect 14,000 jobs.
Methyl bromide currently prevents that from happening.
Louisiana would not do much better. Our rice mills depend on
methyl bromide to meet Food and Drug Administration cleanliness
standards. Louisiana strawberry growers — a $10.7 million indus-
try— will suffer immeasurably, as will the tree nurseries and our
reforestation efforts.
Members of the Subcommittee, the phase-out of methyl bromide
will hurt agriculture in the northwest and the southeast, the grain-
producing states — California, Florida, Michigan, New York and
Texas.
Narrowly stated, in terms of jobs and income, the economic im-
pact of the U.S. phase-out will be significant.
For example, the U.S. Department of Agriculture studied just 21
crops in five states and projected $1.5 billion in direct economic
272
losses. But dollars do not begin to describe the impact of America's
pending loss of methyl bromide.
The loss of methyl bromide will contribute to the slow but clear
loss of American food production independence. For more than a
decade, American growers have been moving their operations to
Chile, Mexico and other nations which respect and encourage farm-
ing. Many American farmers simply will not be able to compete in
the U.S. market or any other without methyl bromide — and not one
other agricultural exporting nation plans to ban methyl bromide.
Our problem is no one here has ever been hungry and we take
agriculture for granted.
Food is as close as the nearest store.
Mr. ROHRABACHER. Dr. PoUet, do you have any overall estimate
as to the cost to agriculture if this was banned?
Dr. POLLET. To the family?
Mr. ROHRABACHER. No, no. Just the cost, overall, in the billions
of dollars.
Dr. PoLLET. Well, just using the information that we had, the
cost from just those five states on those 21 commodities was a bil-
lion and a half dollars.
Mr. ROHRABACHER. Billion and a half dollars.
Dr. POLLET. To supplement that, you'd probably have to multiply
that number several times over to get anywhere close to what it
would be.
Mr. ROHRABACHER. Okay. Well, that's substantial. Proceed.
Dr. PoLLET. The loss of methyl bromide will affect American nu-
trition at a time when our own government urges us to eat five
fresh fruits and vegetables daily as a means of preventing cancer
and heart and circulatory disease.
Most farmers are lucky to make a profit a few times a decade.
The loss of methyl bromide does not simply mean lower yields. It
means fewer farmers with lower jdelds, higher prices, reduced
quality, and a decreasing likelihood that Americans will eat right.
The loss of methyl bromide will affect America's ability to fight
world hunger. The government of India — at a recent meeting of the
nations participating in the Montreal Protocol — said that the loss
of methyl bromide will seriously affect food storage.
The government of Kenya warns of food riots if methyl bromide
is banned.
Ironically, Mr. Chairman, the loss of methyl bromide will have
some negative impacts on the environment. I already have men-
tioned that reforestation may be harmed by this phase-out. But po-
tentially more damaging would be agriculture's return to several
liquid and solid chemical pesticides which could upset existing IPM
programs which have reduced pesticide usage.
Removal of methyl bromide would therefore be in opposition to
the President's program to reduce pesticide usage and would in-
crease pressure on environmental and water quality controls and
worker safety.
I say potentially more damaging because EPA already has
banned or severely limited the use of all of these chemicals and will
not guarantee that any will be available after the January 1, 2001,
phase-out of methyl bromide.
273
Farmers simply do not have true alternatives to methyl bromide
at present and if something new is developed now, it would require
ten-plus years and $50 to $100 million to get it through the re-
quired process before it would be available to the agricultural com-
munity if it passes all the tests.
There is no such alternative on the horizon.
Therefore, let us assume that there are no uncertainties about
methyl bromide's impact on the ozone layer. Will the most optimis-
tic environmental benefits be greater than the damage we will
cause with this phase-out?
Then let us assume, as so many others have concluded, that we
don't know if a phase-out of methyl bromide will have any impact
on the ozone layer. Are we recklessly destroying American agri-
culture with this phase-out?
I end my statement with that question, but would be pleased to
answer the Subcommittee's questions.
[The complete prepared statement of Dr. PoUet follows:]
274
^^A^^ Louiilina Stale University
Ll^*%J Agricultural Center
^-» "^-^ Louisiana Cooperative Extension Service
Mailing Addrass P 0 Boi 25100
Baton Rouge LA 70884-5100
Oflica: KnappHag
(504) 386-4141
Fax: (504) 388-2478
INFORMATION PROVIDED BY:
/^ DR. DALE K. POU^IySPEClAUST
V.^^ KNTOMOLOey PROJECT
LA CX>OPERATIVE EXTENSION SERVICE
BATON ROUGE, LA
, A SMI* nvtiwr in M* CaopaoKw Enaralen ^aMm
275
Hearing before the Subcommittee on Energy and Environment
Committee on Science
United States House of Representatives
Wednesday. September 20. 199S
Statement of Dale Pollet, Ph.D.
Project Leader, Entomology
Louisiana Cooperative Extension Service
Mr. Chairman, Congressman Hayes, Members of the Subcommittee, my name is Dale Pollet.
I am entomology project leader for the Louisiana Cooperative Extension Service. My full
credentials are part of the written record submitted to the subcommittee.
You have asked that I address the economic impacts of the phaseout of methyl bromide.
Attached to my written statement are various well-accepted economic analyses. They
consistently show that the loss of methyl bromide will severely impact American farming and
food production.
American farmers depend on methyl bromide to grow, store, transport and process more
than 100 vegetables, fruits, grains and fiber.
Mr. Chairman, in your state of California, the phaseout will severely harm the production
of grapes, strawberries, carrots, walnuts, pecans, cherries and other berries, rice, citrus,
tomatoes, peppers, plums and melons.
If the ban takes effect, California's fast growing agricultural export business will come to a
stop since Japan and other major markets reqtiire that imported produce must be fumigated
with methyl bromide. The Ports of Los Angeles, San Diego and Oakland will lose
substantial revenues. Methyl bromide is also used in the ports of New Orleans and Baton
Rouge to fumigate cut flowers, grains, vegetables, propagative plant material, lumber and
lumber products. Oakland's American Presidents Line reports that it alone will lose $50
million in revenues annually. Introduction of a new destructive pest into California would
cost farmers in that state $12 billion and would affect 14,000 jobs. Methyl bromide
currently prevents that from happening.
Congressman Hayes, Louisiana will not do much better. Our rice mills depend on methyl
bromide to meet Food and Drug Administration cleanliness standards. Louisiana strawberry
276
growers ($10.7 million industiy) will suffer immeasurably as will tree niu^ries and our
reforestation efforts.
Members of the Subcommittee, the pbaseout of methyl bromide will hurt agriculture in the
Northwest and Southeast, the grain-producing states, California, Florida, Michigan, New
York and Texas. Narrowly stated in terms of jobs and income, the economic impact of the
U.S. phaseout will be significant For example, the U.S. Department of Agriculture studied
just 21 aops in five states and projected $1.5 billion in direct economic losses. But, dollars
do not begin to describe the impact of America's pending loss of methyl bromide.
• The loss of methyl bromide will contribute to the slow but clear loss
of American food production independence. For more than a decade,
American growers have been moving their operations to Chile, Mexico
and other nations which respect and encourage farming. Many
American farmers simply will not be able to compete in the U.S.
market or any other without methyl bromide - and not one other
agricultural exporting nation plans to bein methyl bromide. Our
problem is no one here has ever been hungry, and we take agriculture
for granted. Food is as close as the nearest store.
• The loss of methyl bromide will affect American nutrition at a time
when our own government urges us to eat five fresh finiits and
vegetables daily as a means of preventing cancer and heart and
circulatory disease. Most fanners are lucky to make a profit a few
times a decade. The loss of methyl bromide does not simply mean
lower yields. It means fewer farmers with lower yields, higher prices,
reduced quality, and a decreasing likelihood that Americans will eat
right
• The loss of methyl bromide will affect America's ability to fight world
hunger. The government of India - at a recent meeting of the nations
participating in the Montreal Protocol - said that the loss of methyl
bromide will seriously affect food storage. The government of Kenya
warns of "Yood riots" if methyl bromide is banned.
277
• Ironically, Mr. Chairman, the loss of methyl bromide will have some
negative impacts on the environment. I already have mentioned that
reforestation will be harmed by this phaseout. But, potentially more
damaging would be agriculture's return to several liquid and solid
chemical pesticides which could upset existing EPM programs which
have reduced pesticide usage. Removal of methyl bromide would
therefore be in opposition to the president's program to reduced
pesticide usage and would increase pressure on enviroiunental and
water quality controls and worker safety.
I say "^tentially" more damaging, because EPA already has banned
or severely limited the use of all of these chemicals, and will not
guarantee that any will be available after the January 1, 2001 phaseout
of methyl bromide. Farmers simply do not have true alternatives to
methyl bromide at present and if something is developed now, it would
require 10 plus years and $50 to $100 million to get through the
required process before it would be available to the agricultural
community if it passes all tests. There is no such alternative on the
borizen.
Therefore, let us assume that there are no uncertainties about methyl bromide's impact on.
the ozone layer. Will the most optimistic environmental benefits be greater than the
damage we will cause with this phaseout?
Then let us assume - as so many others have concluded - that we don't know if a phaseout
of methyl bromide will have any impact on the ozone layer. \re we recklessly destroying
American agriculture with this phaseout?
I end my statement with that question but would be pleased to answer the Subcommittee's
questions.
278
REFERENCES
1. The Biological & Economic Assessment of Methyl Bromide
by The National Agricultural Pesticide Impact Assessment Program
2. Comparing the Benefits and Cost of EPA's Proposed Phaseout of Methyl Bromide
Dudley, S. and Mannix, B. - Methyl Bromide Working Group
3. California Agriculture July - August 1995 - Vol. 49 Number 4
4. Monitor Vol. 1 No. 1 Spring/Summer '94
5. IFC Newsletter Bulletin 30 August 1995. Great News for Methyl Bromide
6. Methyl Bromide Working Group
7. American Forest and Paper Association - AFPA Final Comments
on EPA's Proposed Rule to Phaseout Methyl Bromide
1. James Sargent - Great Lakes Chemical Company, West Lafayette, Indiana
2. Charles Welchel - USDA, APHIS, New Orleans, LA
3. Jeny Bartlett - Degesch, Reserve, LA
4. Doug Curtis - Hendrix and Dail, Greenville, NC
5. John Pyzner - LA Cooi)erative Extension Service, Calhoun, LA
6. James Boudreaux - LA Cooperative Extension Service, Baton Rouge, LA
7. Tad Hardy - LA Department of Agriculture & Forestry, Baton Rouge, LA
9. Dalton Monceau - The Industrial Fumigant Company, Jennings LA
10. Lynn Mayes - The Industrial Fumigant Company, Olathe, KS
11. Allen Fugler - LA Pest Control Association, Baton Rouge, LA
279
Mr. ROHRABACHER. Thank you very much. Interestingly enough,
my district has very few farmers. But one was visiting my office
just the other day, a young man who runs a strawberry farm.
He brought his issue up, independent, not knowing that I was in-
volved in this hearing whatsoever, and just told me how devastat-
ing this was going to be to his personal and his family income and
to his business in general.
We have a vote on, as you can tell. I think what we will do is
I will call a recess and I will come back, and when we come back,
that will be the last recess we take and we will go into some ques-
tions and get this hearing done with.
And let me just say, I think that this has been a fantastic panel.
I think already you've really raised some important questions and
I want to see some discussion between you and hopefully, I'll go
vote and we can come back and have that discussion.
So I thank each and every one of you. I'm sorry for making you
wait another 10 minutes.
We are recessed for 10 minutes.
[Recess.]
Mr. ROHRABACHER. The Subcommittee will reconvene.
First of all, let me say for everyone to hear, I remember, and I'm
not going to go through some of the things that I've remembered
in other hearings and everybody is sick and tired of hearing these
memories that I've got of horror stories that didn't turn out to be
true, whether we're talking about the ozone hole or these other
things.
I do remember one, however, when I was in my younger years,
when they banned cyclamates.
Do you all remember cyclamates?
Now I will hope that the panel will correct me if I am wrong, if
my memory has some sort of ozone holes in it. [Laughter.]
But that about a year or two ago, they decided that they were
wrong about cyclamates and that cyclamates actually weren't the
health threat.
And what had happened was the American industry put hun-
dreds of millions of dollars into developing this, basically a means
of having a diet drink and helping people's health, by the fact that
they could drink a cola and have less calories and thus, build up
less fat or whatever, from drinking cola.
And then, all of a sudden, the FDA decided — and there was some
evidence that would indicate that there was going to be a health
threat. Cyclamates were banned, but cyclamates were never
banned in Canada.
And so, when they came back, what we saw out of this was not
something that made us any better, but instead, we saw about a
billion dollars' worth of wealth evaporate from our society. And our
economist friend there understands that when you do things like
that, that actually means that people are not as well off.
People's lives, people don't eat as well because of things like this.
They don't live at a higher standard of living. There's an anxiety
level among poor people who might be a notch or two higher in the
economic order if we didn't waste that kind of money.
And when you waste money like this in a society, there are
health implications to wasting the money in the first place.
280
And what we are looking at now, and one of the things that we
want to focus in on with this panel, is whether or not the benefits
in terms of, number one, we've talked about the risks in the first
panel, but what are the costs and the benefits of what has been,
of the solution that we've heard in terms of banning CFCs?
Let me first say that I — and I repeat this for the third time in
the hearing — I am not impressed with lists of people, these are all
the guys that agree with me, and look how little the list is for the
people who disagree with me, and thus, my arguments hold more
water.
That doesn't go with me at all because I have, in my life, been
a single voice on several issues and after a few years, finding that
everybody agreed with me after a few years, when in the begin-
ning, nobody agreed with me.
What counts are the arguments on your side, do they withstand
scrutiny and do they withstand the challenge of someone else's po-
sition?
I'd like to ask Ambassador Nichols, basically today — ^Adminis-
trator, not Ambassador. Excuse me.
Ms. Nichols. I appreciate the promotion.
Mr. ROHRABACHER. That's all right. [Laughter.]
You had stated in your testimony on August 1st, before the Com-
merce Committee, that your cost/benefit analysis was 1000 to 1
ratio and today you seem to testify that it was 700 to 1 cost/benefit
ratio.
And some of my staff who read your former testimony as well as
your current testimony sort of picked that up. We were kind of
wondering what happened in between there?
Ms. Nichols. I went back, actually, and asked the staff — I think
I may have mentioned this in my earlier summary of the testi-
mony— to give a more conservative estimate based on not including
the information about the melanoma cancers versus the
nonmelanoma cancers because, as you heard from the medical wit-
nesses earlier, although there's a pretty strong correlation between
the radiation and the melanoma cancers, there's a question mark
about exactly what level of exposure causes what amount of cancer
risk.
And so, I simply decided to exclude that data and come up with
a lower number.
Mr. ROHRABACHER. That's a very good answer.
Now we've talked a little bit in the hearing about the growing
black market production of CFCs, especially in China and India,
and possibly Russia. But also, I might add, I come from California
and people are talking about that now in terms of being a major
Mexican export to the United States, just like some other products
that are illegal.
So what is the actual benefit? If we end up with a black market
in these things, what's the actual benefit? Isn't the damage that's
being done to our economy and the fact that we're paying so much
more, the fact that it's going into a black market rather than a
market where people are pajdng taxes and it's being done above
the board?
What is the offset on this?
281
Ms. Nichols. Let me just make one comment. I think Mr. Fay
would also like to say something, if that's all right.
Mr. ROHRABACHER. That's fine.
Ms. Nichols. I just wanted to say that I had an opportunity to
actually visit China for the Administration as part of the signing
of a research agreement.
And while I was there, I visited the ministry in China that has
control over their CFC production and actually was shown the CFC
factory that they used to have that has now been shut down in
compliance with the Montreal Protocol.
It's true that the rest of the world is lagging behind the U.S. in
the phase-down. The developing countries were given an extra ten
years before they had to completely get out of the business of pro-
duction.
But if you look at the growing market in China for refrigerators,
which is the appliance that everybody buys — the minute they get
a TV set and get a little extra money, they get a home refrigerator
so that they don't have to go to the market every day.
The refrigerators that they are now bujdng because of the Mon-
treal Protocol are CFC-free refrigerators and they're more energy-
efficient.
So that, in the long run, this is helping the global situation.
Mr. RoHRABACHER. Does anyone on the panel have anything that
is contrary to that one thing about China?
Mr. LiEBERMAN. I do know that there was one Chinese official
who was threatening to build 100 more CFC facilities recently un-
less they get more money.
Mr. Fay. Let me add to that.
There's been a lot of misinformation about the developing coun-
tries.
China just announced last week that they are accelerating their
phase-out. They're not legally required to phase out. They're al-
lowed to grow under the treaty. That's designed because of their
tremendous needs for the population.
But they have announced their goal just last week of accelerating
the phase-out to the year 2005.
Russia is not in compliance with the protocol. I can tell you that
very frankly. Russia has announced they are closing down all of
their factories, with the exception of one, which will continue to
manufacture, and we think that the Russian production is the larg-
est source of black market material in the United States right now.
Mr. RoHRABACHER. But they've announced they're closing.
Right?
Mr. Fay. They have announced they're closing.
Mr. ROHRABACHER. Announcements in tours are very impressive.
Mr. Fay. Well, it's very difficult to get anybody's attention in
Russia on anything right now. And closing CFC plants, surpris-
ingly, is pretty high on their priority list, but it's not right up
there.
Mr. ROHRABACHER. Mr. Fay, do you believe that the black mar-
ket problem in CFCs is going to decrease, then?
Mr. Fay. As soon as the Congress eliminates the excise tax, yes,
sir, I do, because that is what's creating the black market, is the
$5.35 tax on the compounds.
282
It's equivalent of a $10-per-gallon gasoline.
Mr. ROHRABACHER. Well, let's move to the Administration.
Will you be supporting this?
Ms. Nichols. I don't think I'm authorized to have a position on
that issue.
Mr. RoHRABACHER. Is the Administration considering supporting
the elimination of CFC taxes?
Ms. Nichols. I'm not aware of £iny such request that's been
forthcoming that I've seen.
I would note, however, for the record, that the proceeds of that
tax do not come to the EPA budget.
Mr. Fay. Mr. Chairman, I would, note as you well recognize, the
tax bills originate in the House. This tax proposal originated with
the Reagan Administration.
Whatever we want to do with it, we'll be happy to work with you
and anyone else who would consider restructuring the tax, either
so that it is to be used for the issue from which you're taking the
money, or at least capping it so that it doesn't continue to grow.
Mr. RoHRABACHER. Did the Reagan Administration really origi-
nate this, or was this something originated in Congress that just
happened to be signed during then?
Mr. Fay. No. The Reagan Administration originated this.
Mr. ROHRABACHER. Is that right? I thought we were against
tEixes.
Mr. Fay. It was. They were. The theory here was it was a wind-
fall profits tax, since we were going to be reducing supply, that,
somehow or other, that the private sector would gain windfall prof-
its.
Therefore, we had to protect them from themselves.
Mr. ROHRABACHER. That shows you the danger of those windfall
profits tax ideas. [Laughter.]
Professor, did you have something to add to this?
Dr. Stroup. Yes. The question, I guess, if the CFCs are being
smuggled in only because of the tax, my question is to EPA or Mr.
Fay, why are the other countries growing larger in their production
of CFCs, given that EPA at least claims that the new refrigerator
technologies and the things actually being produced are cheaper
than CFCs?
So the consumers are benefited by this, not harmed by this. If
that's true, why aren't American companies underselling the CFC
machines and the CFCs abroad?
Mr. Fay. The fact is that the developing country plans, frankly,
have them growing in both technologies right now. We just assume
they only grow in the new technology.
But if they have the production capacity in existing plants, they
have been looking to expand that capacity by debottlenecking
plants.
Mr. ROHRABACHER. Okay. Let me note that I am known in China
as a China-basher.
It's not really accurate. If the Chinese do things, if the Chinese
regime does things, if it as a regime has the policies that are pro-
democratic and are amicable to the rest of the world, that's fine.
I would applaud them.
283
But, usually, this monstrous regime does many things that are
just opposite to that and sometimes they actually take people
around to gulag camps that are nothing more than playgrounds
until the person leaves.
And I'm not sure whether or not — I mean, I know that they've
been stealing from California. Not only do they steal our CDs £ind
our records and the creations of our artistic community, but to rub
it in, the army has built these factories and they actually reproduce
this and all the profit from reproducing it and selling it overseas
in competition with our own people goes to help strengthen the Red
Chinese army.
Now they've made an announcement that that practice is stop-
ping, too. I'm anxious to see that stop and I hope that they are tell-
ing the truth.
I wouldn't bet my refrigerator on it.
Mr. Fay. Our attitude on that is, just as arms control with the
Russians and the Chinese, trust but verify.
Mr. ROHRABACHER. Right. Right. One issue that we'd like to dis-
cuss, and Ms. Rivers, you have some time now as well to ask as
many questions as she'd like. Or Mr. Ehlers.
What about the issue that the alternative is really just as poten-
tially damaging as what you're getting rid of?
WTiat about this issue that, like with asbestos, where they said,
oh, you've got to get rid of all the asbestos. And later on, we found
out, by trying to get rid of it, we actually put more people at risk.
What about all of these substitutes actually being worse than the
original problem in terms of the risks to people's health?
Ms. Nichols. Mr. Chairman, I think Congress learned some les-
sons from the cyclamate issue, perhaps, or others, in terms of alter-
natives and wrote in a provision in the Clean Air Act that required
testing of alternatives to CFCs to make sure that they, number
one, were better from the ozone-depleting point of view, and two,
didn't create other unintended consequences for health or the envi-
ronment.
Mr. ROHRABACHER. Well, what about this one that creates acid
rain? And the other one that creates a cancer problem for the wet-
lands.
Ms. Nichols. To the best of my knowledge, the acid rain issue
is a phony issue. It was alleged at one time that there would be
more energy used because the substitutes wouldn't be as efficient
as the CFCs, and therefore, you'd have more power plants churning
out more sulphur oxides and causing acid rain.
Mr. ROHRABACHER. All right.
Ms. Nichols. Not true.
Mr. ROHRABACHER. That's not true.
Ms. Nichols. As it has happened
Mr. ROHRABACHER. There was just a scientist — I think it was Mr.
Singer, in fact, testified pretty early
Ms. Nichols. Well, the facts have simply turned out to the con-
trary, that the substitutes have been part of the redesign of equip-
ment to make it more efficient. And we're seeing actual savings in
energy used by these refrigerants.
So we were right, for once.
284
Mr. ROHRABACHER. Unfortunately, I didn't bring that up to the
panel of scientists earlier because I do remember the point specifi-
cally that CFCs are a rather efficient way.
But now what you're saying is actually the new alternatives are
more efficient.
Ms. Nichols. The alternatives, per se, aren't what's causing the
improvement in efficiency. It's that in designing the products in
order to use the new refrigerants, the manufacturers have also re-
designed other aspects of the equipment.
So that the total product, which is what you buy, is more energy-
efficient.
Mr. ROHRABACHER. Mr. Lieberman is about ready to jump out of
his chair. So please move forward.
Mr. Lieberman. This energy-efficiency argument is extremely
misleading.
Actually, CFCs are, in almost every application, more efficient,
not less efRcient, than comparable non-CFC systems.
It is true if you replace a 25-year-old dinosaur of a CFC system
with a brand new, state-of-the-art, non-CFC system, you'll see an
improvement in energy efficiency.
That improvement has nothing to do with the refrigerant being
used. It has to do with technological improvements independent of
the refrigerant used.
And as a matter of fact, if CFCs could still be used in state-of-
the-art equipment, we would see a gain in efficiency.
So EPA actually has energy-efficiency on the wrong side of the
ledger. Compared to a no-phase-out scenario, none of us are talking
about that, but compared to a no-phase-out scenario, we would see
equipment far more efficient than anything available today.
Mr. Fay. I'm going to flat out disagree with Mr. Lieberman.
Mr. ROHRABACHER. All right.
Mr. Fay. You've got two lawyers up here talking about stuff that
we ought to have engineers discussing, Mr. Chairman.
But, frankly
Mr. ROHRABACHER. That's all right. We've got lawyers making
lawyers making laws here, too. [Laughter.]
Mr. Fay. There seems to be a suggestion that the industry glee-
fully spent $6 billion retooling and investing to convert out of these
compounds so they could do it again because they know they're not
quite as good.
Well, that's just not true.
The industry — ^these compounds that we've converted to have
been around a long time. These compounds, we have spent nearly
$100 million. They are the most thoroughly studied chemicals in
the history of chemical development.
There are thousands of chemicals out there that we use on a
daily basis that we have no clue what their impacts may be on
health, environment, whatever.
The user industry, the producer industry studied these from a
toxicity standpoint, from £in environmental standpoint in terms of
breakdown products, from an energy-efficiency standpoint.
And for these people to sit here and somehow make light of the
investment that these industries made in good faith, and these
285
products, is absolutely ridiculous. And to make them and be wrong
is even worse.
Mr. ROHRABACHER. Well
Mr. Fay. Now wait a minute. You talked earlier, in the earlier
panel about policy-making by press release. And it's the same kind
of — excuse my language — the same kind of crap we get from either
the environmental side — excuse me — the environmental side or
these advocacy groups who want to come in and use us as their fod-
der.
It's got to stop. That's what the American people are sick of.
The industry came in and said we can solve this problem. Here's
how we think we'll do it, we can do it. Here's how long we think
it will take.
And now they want it to stop.
Mr. ROHRABACHER. Mr, Fay, we should hesitate to use that lan-
guage.
Mr. Fay. I'm sorry.
Mr. ROHRABACHER. Okay. Thank you.
Mr. Fay. I apologized in advance.
Mr. ROHRABACHER. I slip at times myself, but I try not to.
Let me shift the argument, then, away from refrigeration to what
Mr. Pollet was talking about in terms of the effect that this will
have on agriculture, because this is totally different than what
we're talking about in CFCs in refrigeration.
Mr. Pollet has made some arguments that ethyl — methyl bro-
mide— earlier on, I was talking about carbohydrates in the air. I
don't want to make a mistake again.
But Mr. Pollet was talking about the billions of dollars that this
will cost and we're talking about not only direct cost of billions of
dollars, but also a loss of competitiveness for American agriculture
overseas, which this is a major impact on our economy, a major im-
pact on the well-being of many families which this is the way they
earn their living.
Could you folks address that?
Mr. Fay. Let me just say, look, I heard every argument this
morning in the earlier panel by Mr. Doolittle, Mr, DeLay that we
made in 1983, okay?
We used to say the same thing. It was only a 60-mile move
south, that you couldn't replace the chemicals.
We found out we could. Does methyl bromide have some serious
problems in terms of being able to limit their use?
Absolutely.
Do we have a problem because when Congress adopted the Clean
Air Act, they didn't put a provision in there for essential use ex-
emptions, which we said you had to do, which they didn't do on the
existing equipment base for refrigerants, which we said you had to
do?
Absolutely.
So we're sitting here saying that the issue is fake, that we've got
all these scientists debating whether it's a real issue or not a real
issue.
Industry and farmers and consumers, they don't have time for
that. We've got to make a policy decision. We're going to move on
and correct the problems with the law, not that debate.
286
Mr. ROHRABACHER. The policy suggestion that you're making
then is that we make an exception for agriculture on this?
Is that what you're saying?
Mr. Fay. If in fact there is a need for an essential-use exemption
for agriculture, yes. But does that mean that they can't do any-
thing? No, it doesn't. We've seen that time and again.
But do they need an essential-use exemption for the existing
equipment base of automobiles? None of that existed. We managed
to get that in 1992 in the treaty by which we're operating. That did
not exist and we managed to get that in there because we finally
got somebody to pay attention.
Mr. ROHRABACHER. Administrator Nichols, is there any support
within the Administration about this type of exemption?
Ms. Nichols. Yes, Mr. Chairman. I have met personally with
representatives of grower organizations here in town, along with
the Deputy Secretary of Agriculture, Rominger. Both of us are Cali-
fornians and maybe that has something to do with it.
But we've also had support from the White House for working on
some specific language that would create the ability to give an es-
sential-use exemption for agricultural uses that cannot be sub-
stituted.
Mr. ROHRABACHER. Let me recommend that the Administration
move forward very quickly on this so that the agricultural interests
and the people who we're talking about here will understand, be
able to take a look at what their alternative is and the alternative
that you're offering.
Ms. Nichols. I think the basic principle, as has been suggested
in other areas, should be that they would be granted in enough
time in advance so that the users would know what was available
to them, but that there would be a careful set of criteria to make
sure that we continue to maintain the incentive for research on al-
ternatives.
Mr. ROHRABACHER. Mr. PoUet, would you like to comment on
that?
Dr. POLLET. Yes. There really are no other materials. You talk
about Telon-2. Telon has been banned in California and it's strictly
for pneumatocides. Whereas, methyl bromide will take out insects,
diseases, and I'm talking about bacteria and viruses as well, nema-
todes, also weed seeds.
And there's no other material on the market, either now or con-
ceivably in the future, that will work that effectively.
If you take that material off the market
Mr. ROHRABACHER. We're talking about an exemption now that
would permit you to use it.
Is that what you're advocating, Mr. Fay?
Ms. Nichols. Excuse me. To be careful about that, it depends on
the use.
There is no single compound that does everything that methyl
bromide does. There's no question about that. Methyl bromide is an
extremely effective biocide. It kills everything in its path.
For certain purposes, there are substitutes.
Mr. ROHRABACHER. But, Mr. Fay, were you advocating that there
be an exemption for this?
287
Mr. Fay. I'm not advocating a blanket exemption for agricultural
uses, no. I'm saying if there's a need for an exemption in these
areas, then that's something that the Congress should look at.
If there's a need for an exemption in other areas, that's some-
thing that the Congress should look at. The Congress should leave
itself some outs in case, just as you say, if the data changes or in-
formation proves to be wrong.
Mr. ROHRABACHER. But you're not willing to advocate that now.
Mr. Fay. An agricultural exemption, just a flat-out blanket ex-
emption?
Mr. ROHRABACHER. For the methyl bromide here.
Mr. Fay. No. No. It's not my issue. We have not worked on the
methyl bromide products. They are late coming into the issue. I un-
derstand that. And in terms of — I can't speak to the availability of
substitutes on that basis.
Mr. ROHRABACHER. Well, let me just say that this gentleman rep-
resents not just himself here. If you listen to what he had to say,
this is really important to the well-being of our country.
Mr. Fay. No, no. I understand that. And as I pointed out, we
made all of the same arguments about 15 years ago.
Mr. ROHRABACHER. Okay. Well, we take him very
Dr. POLLET. Let me just say this. It's not just agriculture. There
are a lot of PCOs and whatnot, use this in the fumigation of homes
for pesticide control, and things like the Formosan termite, which
is extremely difficult to control.
It's probably one of the most economical ways of doing it.
If you have to do something with the Formosan termite, it usu-
ally takes you three or four applications of other materials.
Mr. ROHRABACHER. Mr. PoUet, thank you very much.
I'm going to turn now to Mr. Ehlers first, and then Ms. Rivers.
Mr. Ehlers. Ms. Rivers.
Mr. ROHRABACHER. Is that right? Pardon me.
Ms. Rivers.
Ms. Rivers. Thank you, Mr. Chair.
I want to ask a sort of bottom-line question. But before I do that,
I want to go back to the issue that Mr. Fay raised because I was
heading in the same direction, which is this whole idea that we
have been condemning public policy being developed in the press
or through anecdote.
And frankly, we've had some problems here on this Committee
sometimes.
And as I was going through the testimony and listening to folks,
two things really jumped out at me that I think I want to ask
about.
One is directed to Professor Stroup. And that was your sugges-
tion that the imposition of the accelerated phase-out of CFCs has
increased the price and lowered the energy-efficiency of refrigera-
tion units and that the effect of this is that fewer people will be
able to purchase home refrigeration, which in turn will cause dele-
terious health effects, such as food poisoning and stomach cancer.
Before I ask my question, it's interesting. We were having a dis-
cussion around a similar topic here around energy efficiency and
the cost of refrigeration. I was amazed when I was able to get data
288
from the Livermore labs that in fact the cost of refrigerators has
gone down significantly over the last 25 years.
I'm very interested in knowing specifically how large the price in-
creases for home refrigeration you project. And where you deter-
mine that these significant health risks come from.
I'm asking, I guess, for your underlying data for both of those as-
sumptions.
Dr. Stroup. Well, first of all, I don't disagree that the price of
refrigeration is coming down. That's not the point.
As Mr. Ben Lieberman said earlier, that relates to two things.
One is the technological trend. We have constant improvement in
automobiles. We have constant improvement in refrigerators. We
have constant improvement in almost everything — computers, you
name it.
Some of that technological trend has, I believe, been soaked up,
so to speak. It's been a smaller decline in the cost of refrigeration
than it would have been, I believe.
What I have read is that CFCs are thermodynamically more effi-
cient than their substitutes. That's the basis for my statement.
Plus what I said earlier, which is that you cannot, I think, make
consumers better off dollar-wise by taking away options from them.
I just don't think that that is likely to happen.
Ms. Rivers. The other thing that was interesting in the Liver-
more data is that there are more kinds, more and different kinds
of refrigerators available than there was 25 years ago.
Dr. Stroup. Sure.
Ms. Rivers. So in fact there's a greater efficiency.
But your answer begs the question, which is, if in fact the actual
cost of refrigeration is not going up and is not likely to go up under
these changes, where do you get the argument that the elimination
of CFC is going to produce greater incidences of food poisoning and
stomach cancer?
Dr. Stroup. If there would have been a 20-percent reduction —
suppose there has been a 10-percent reduction. I don't know what
that number really is. But suppose there could have been a larger
reduction.
Then refrigerators would be more available. Then they would be
larger. Then the food poisoning would fall because the potato salad
brought in from the picnic is more likely to be refrigerated and so
on.
Ms. Rivers. So you're sa5dng that it's purely hypothetical. You
have no data to suggest that this would actually happen.
Dr. Stroup. I don't know what the partial is. All I know is I read
that the thermodynamic efficiency of CFCs is greater than any of
its substitutes.
And how can you conclude anything else?
Ms. Rivers. And you say that since there is an efficiency dif-
ference, that your projection is that refrigeration will cost more.
So that it's pure speculation on your part, is what you're saying.
Dr. Stroup. It's pure logic. And I have no data beyond that logic.
That's correct.
Ms. Rivers. Thank you. The other similar issue that I would like
to raise, and this I would like to address to Mr. Lieberman.
289
And that is relative to statements that you presented in — I be-
heve it's The Washington Times. Yes, The Washington Times. Ar-
guing that the death of hundreds of people in Chicago was a direct
result of these changes around CFCs.
And I would like to know, particularly given that Mr. Ted Rees
from the Air Conditioning Institute immediately contradicted you
and the Cooke County coroner's office also immediately contra-
dicted you.
What were the underlying data that you relied on to make your
comments in the paper?
Mr. LlEBERMAN. I think if you read my article and if you submit
it to the record
Ms. Rivers. I have.
Mr. LlEBERMAN [continuing]. You'll see that I was actually very
careful. I was speaking in hypothetical terms.
Mainly, this was an article that the Chicago heatwave should be
a warning for the future, that if further reductions in the availabil-
ity of refrigerants and further increases in costs are going to be im-
plemented, is being discussed by the parties of the Montreal Proto-
col, namely, a more drastic reduction in the phase-out, or drastic
acceleration of the phase-out of HCFC-22, if that was to occur,
then future heatwaves would definitely be affected.
I was very, very careful to say that — I don't remember my exact
language, but I said that there's no evidence that anyone was actu-
ally hurt. But the possibility cannot be discounted.
I'm just theoretically saying that, in broad terms, if you make
air-conditioning more expensive, you will make it less available.
Ms. Rivers. So what you're saying then is you just used the
death of 500 people as a platform on which to make your point.
Thank you.
Mr. LlEBERMAN. Yes.
Mr. ROHRABACHER. I think the witness also was suggesting that
there were enough caveats to cover him. We've heard a lot about
caveats.
Ms. Rivers. You mentioned that earlier, that caveats are often
used as an opportunity to not tell the truth.
Mr. Rohrabacher. No, no. That's right. Caveats are — how-
ever
Ms. Rivers. I have one more question, I'm sorry. And this is the
bottom-line question that I made reference to.
Mr. Rohrabacher. Maybe we can let Mr. Liebermann just have
one chance to answer.
Ms. Rivers. Okay.
Mr. Rohrabacher. Go right ahead, Mr, Liebermann.
Mr. LlEBERMAN. I suppose I shouldn't have written an article
that gave them some fodder to discredit me.
I'm a newcomer. I haven't written much, so there wasn't much
to pick on me for, and this was the best they could do.
Read it yourself. You'll see,
Ms. Rivers. It's pretty good, you have to admit.
Mr. Rohrabacher. Mr. Liebermann, I wouldn't apologize,
Mr. LlEBERMAN. Read it for yourself.
Mr. Rohrabacher. I wouldn't apologize. All I would say is, when
I saw your article, I remember that I had been driving around all
290
summer in a car without air-conditioning and I was sweating and
I felt really bad this summer.
I had a tendency to think that maybe this had something to do
with the increase in the price of freon, that it had something to do
with this CFC ban.
I don't think it was a jump of logic to suggest that maybe some
other people up in Chicago were sweating and maybe it had a dele-
terious effect on their health.
I don't know any information about it, but I was sure sweating
and I was angry about it. So apparently you were, too.
Mr. LlEBERMAN. I would also add that the hypotheticals that
were necessary to come up with cost/benefits of $32 trillion in
EPA's regulatory impact assessment I think also deserve a closer
look as well.
Mr. ROHRABACHER. Okay.
Mr. LlEBERMAN. I don't know if there are $32 trillion around.
Mr. ROHRABACHER. Ms. Rivers, do you have one more question,
please?
Ms. Rivers. I do.
Mr. ROHRABACHER. And then we'll go to Mr. Ehlers.
Ms. Rivers. Okay. I'd like to address this to Ms. Nichols.
And that is, I've heard a lot of arguments about the economic
consequences of continuing with the elimination of these chemicals.
But in talking to a variety of people, I have also heard people
talk about the economic effect of rolling back and not going for-
ward.
Could you speak at all to the costs to industry or the country in
general if we choose now to abort in the middle of this process?
Ms. Nichols. We have not done an analysis of the effects, let's
say, of the proposal that is in Mr. Doolittle's "Dear Colleague" let-
ter to rollback, partly because the effects are somewhat unknow-
able, since it's a violation of the Montreal Protocol Treaty. We don't
know what the effects on the rest of the world would be in terms
of the overall effect on the ozone hole.
So you'd have to just look at the cost to industry and the invest-
ments that have been made on that side in reliance on the current
date.
We know, obviously, some companies are actually moving ahead
of the deadline to get ahead and we'd have to go back and do a
more careful look at that.
So I can't really give you any numbers right now. But, clearly,
directionally, it would be a disadvantage to those firms that have
made the investment.
Ms. Rivers. Mr. Fay, can you speak to that?
Mr. Fay. It would be hard to say what the costs are because the
phase-out is complete. There are — ^but for a few exceptions, there
are no major equipment manufacturers in this country any longer
using CFC compounds.
And the chemical companies, what they make from now on will
only be what they're allowed to make as a result of the exemption
for developing countries and to ship overseas.
I can tell you that if it's going to come from somewhere, if you
roll back the phase-out, if the material could somehow find its way
legally into the country, it would come in from China, India or Rus-
291
3ia, because there are no companies in this country that I'm aware
jf who have any intention or interest in — I don't know how many
people got back into cyclamates, Mr. Chairman, but they're not
looking into restaring their CFC plants.
Mr. ROHRABACHER. I would agree with the witness that that's
maybe true of companies.
I can tell you that there are a lot of people out there who are
looking for freon for their air conditioner.
Mr. Fay. There is plenty of refrigerant available. The production
bas not ended from that standpoint this year.
Mr. ROHRABACHER. Yes.
Mr. Fay. It's expensive, yes.
Mr. ROHRABACHER. That's right, yes. If you earn as much as a
Washington lawyer, it's not so bad. But if you're some regular
buman being, it's a pretty expensive proposition.
Mr. Fay. When the Congress puts a tax on it, the equivalent of
1 10 a gallon on gasoline, it's going to be expensive.
We were opposed to the tax. We didn't support it. I mean, it's ex-
pensive.
Mr. ROHRABACHER. Boy, I'll tell you. I don't remember Ronald
Eleagan doing that, but I guess he did. [Laughter.]
Mr. Fay. The other side of the aisle very gleefully adopted it, I
can assure you. [Laughter.]
Mr. ROHRABACHER. They never met a tax they didn't like.
Mr. Lieberman, did you want to say something. You got kind of
beat up there.
Mr. LIEBERMAN. Well, I do want to add that the Doolittle bill ac-
tually does roll back the tax. It doesn't eliminate it. It rolls it back,
Congressman Doolittle being a moderate, obviously.
Mr. ROHRABACHER. Right. Okay. WeU, thank you very much.
Mr. Ehlers.
Mr. Ehlers. Thank you, Mr. Chairman. It's been a long day, so
[11 be brief.
I would just like to pin down this efficiency issue a little bit bet-
ter.
Mr. Lieberman, Professor Stroup, you both made the comment
that the thermodynamic efficiency of HFCs is lower than the CFCs.
Can you give me the data on that? Why is that? How much lower
is it?
Mr. Lieberman. I don't have the exact data, but I can certainly
give that to you and submit it for the record.
Mr. Ehlers. Mr. Fay, perhaps you know.
Mr. Fay. I don't have the precise figures. Technically, from a
chemical-for-chemical basis, that is true.
Mr. Ehlers. By what percentage?
Mr. Fay. I couldn't tell you. But they've been able to engineer
around that.
A couple percent, I'm told.
Mr. Ehlers. That's extremely small because the variation of effi-
ciency of compressors is greater than that, depending on how care-
fully you build them, what the tolerances are, and so forth.
So it's basically a non-effect, then.
Mr. Fay. Well, on a global scale, a couple percent actually ends
up being a lot. But the chemicals themselves
292
Mr. Ehlers. No. I'm saying, if we're worried about a couple per-
cent, then we ought to worry about the engineering of the compres-
sors, too.
Mr. Fay. Exactly. That's exactly it.
Mr. Ehlers. Because that exceeds a couple percent variation.
Thank you, Mr. Chairman. I think I made the point.
Mr. ROHRABACHER. Thank you very much. And I would like to
note for everyone gathered that we do have several new pictures
on the wall.
There's a new painting over here. I imagine that has something
to do with the ozone hole. [Laughter.]
And there's another one over here [indicating]. I think that is
less abstract. I think that has something to do with the aerospace
industry.
I have thoroughly enjoyed your testimony today.
Mr. Ehlers. Mr. Chairman, I believe that's a pollution vacuum.
Mr. ROHRABACHER. A pollution vacuum.
Mr. Ehlers. That's sucking all the pollution away from the earth
and right out to the sun. [Laughter.]
Mr. ROHRABACHER. This is why we have a scientist here, to open
and broaden our horizons of the possibilities and potentials of the
human mind.
I want to thank you all. I appreciated your testimony. This has
been — I think it's been a very fine hearing, where we had a con-
trast of opinions, which is what the purpose of this was.
I appreciate all of you coming. Thank you very much.
The hearing is adjourned.
[Whereupon, at 4:16 p.m., the hearing of the Subcommittee on
Energy and Environment was adjourned.]
APPENDIX
JIMMY HAYES
WASHINGTON OFFICE;
UlfvWt*. LA 70901
CongrtSB of the lanittd States
Jl^oust of Sleprnfentatibnt
aaSasljington, BC 20515-1807
DISTRICT OFFICES: — , ^
.ooE«».«.k,n l|oiu(e of Sleprnfentatibnt
September 20, 1995
JJ/amv/ Hay^
Member or Congress
Opening Statement by Congressman Jimmy Hayes (D-LA) ,
Ranking Democrat on the House Subcommittee on
Energy and Environment, regarding
the Ozone Depletion hearing
Mr. Chairman, the issue of stratospheric ozone depletion that
is before our Subcommittee today may be somewhat unclear in its
public policy and economic implications, but not in its scientific
foundations.
Theories regarding the adverse impact that both natural and
man-made Chlorof luorocarbons (CFC's) have had on ozone depletion
enjoy some of the most broad-based support of any matter of
environmental interest. Principles of chemistry confirm that CFC's,
which are inert and stable substances on earth, react with ozone in
the upper atmosphere to draw away oxygen molecules, thus destroying
the ozone.
The agreement of over forty nations under the Montreal
Protocol and subsequent amendments represented the acknowledgement
of the policy makers, industries, and scientists throughout the
developed and developing world that a problem existed and that a
collective solution was the only workable strategy to address the
situation. At the time of the Protocol, U.S. manufactures sold
about $750 million in compounds annually to about 5,000 customers
in refrigeration, air-conditioning, automotive, plasticfoam, and
electronic industries. Those industries then produced $27 billion
in goods and services per year directly dependent on CFC's.
The Sxibcommittee is well aware of my position on how
government, more specifically the federal government, should
perform its oversight function over the environment. We must
utilize the best available and most credible science --peer
reviewed science -- and we must ensure that relevant risks, costs,
and benefits to society are appropriately weighed. I firmly
believe that, with only limited fiscal, natural, and human
resources, it is indeed government's responsibility to allocate its
resources in a way that maximizes their effectiveness. We can
(293)
294
protect our environment without writing thousands of pages of
regulations and prohibitions. We must focus on the most pressing
problems -- those that pose the most risk to our society, not those
that yield minimal benefit for too high a price.
It is for these reasons that I believe that postponing the
phase -out of CFC's would be a waste of our limited resources. When
factoring the investments that have already been directed toward
the phase-out in terms of time, money, human capital, etc..., the
costs involved in the delay would surely outweigh the benefits.
Economic principles tell us that choices boil down to utility.
Billions of dollars have already been spent to develop viable
substitutes and it is my understanding that those products and
technologies are on-line to take over the market. Businesses which
produce and are dependent on CFC's would not have changed their
production and utilization processes unless some benefit -- utility
-- was gained that justified these important investments.
This is not to say that there are not issues which remain in
doubt. After all, someone once said that "everyone knows in
research there are no final answers, only insights that allow one
to formulate new questions."
For example, I fully recognize and agree with the legitimate
concerns of some of my constituents that the cost associated with
replacing or repairing refrigerators, car air conditioners, or
commercial chillers will continue to be exorbitant. Mr. Lieberman
makes this point in his testimony. The industry has made the
capital equipment problem among its top priorities. It is my hope
that stockpiles of CFC's and grandfathering some of this equipment
may acceptably resolve some of this dilemma. I will work with the
Chairman, my constituents, and other interested stakeholders to
move our policy in a suitable direction.
Finally, I wanted to touch on the much more complex issue of
the phase -out of methyl bromide. Methyl bromide's primary uses
center around pre-planting treatment of soils to control insects,
pests, fungus, and certain other diseases. It can also be employed
for post harvesting fumigation of agricultural commodities for
prevention and removal purposes as well as structural fumigation
where grain is stored.
Whereas research into CFC's effect on ozone depletion has been
conducted for decades, scientists have only tied methyl bromide to
ozone depletion since 1991. Unlike CFC's, data does not as
explicitly and unequivocally assert that man-made occurrences of
bromine in the atmosphere outnumber natural sources .
295
Under Title VI of the Clean Air Act Amendments, methyl bromide
has been classified as exhibiting ozone depletion potential (ODP)
and is targeted for phase-out by the year 2001. It is worth noting
that methyl bromide is not part of the phase -out schedule under the
Montreal Protocol dealing with the elimination of CFC's worldwide.
U.S. phase- out is unilateral. While the upcoming Protocol
conference in Vienna is expected to discuss methyl bromide, the
disagreement in the scientific community over its precise ODP and
its impact on meeting the ozone stabilization deadlines, no
decisions regarding its international disposition are likely to be
made. No other major agricultural exporting nation plans to ban
methyl bromide.
With this in mind, I welcome Dr. Dale Pollet of the Louisiana
Cooperative Extension Service to the Subcommittee to testify on the
threat to the agricultural community of a unilateral phase-out of
methyl bromide. Dr. Pollet received his Ph.D. in Entomology from
Virginia Tech and his B.S. from Louisiana State University. He has
been a leader in our state of addressing the impacts of a number of
pest control methods and been involved in the development of the
Integrated Pest Management efforts with the Louisiana Cooperative
Extension Service.
In his statement. Dr. Pollet points out the $1.5 billion in
direct economic losses due to a premature phase -out schedule of
methyl bromide prior to the development of viable substitute
products. He also alludes to the consequences of a ban on the rice
mills of Louisiana, many of which, I might mention, are located in
the Seventh District.
According to USDA's own data, of the estimated 135 commodities
that require fumigation as condition of import or export, only 17
have an alterative treatment currently approved and 93 are under
review. The three chemicals which perform these substitute
functions are being examined by EPA for potential carcinogenic
effects. Remember also that these are all post harvest function
which only account for approximately 5% of methyl bromide uses. No
acceptable substitutes have been approved for pre- treatment.
I would conclude by saying that even if substitute
technologies were available today, it could still take up to ten
years to ensure approval under the FIFRA process. Methyl bromide
is the alternative to many chemicals long banned by federal
regulators, and herein lies the predicament. Assuming that
scientific consensus is reached on the ozone depletion effects of
methyl bromide, a process must be formulated to ensure that the
options to methyl bromide produce an overall environmental benefit.
I applaud the Chairman for the timeliness of this proceeding
and am looking forward to hearing the testimony.
296
Statement of Rep. Henry A. Waxman
Before the Subcommittee on Energy and Environment
Committee on Science
September 20, 1995
The ozone depletion program in the Clean Air Act is one of the
strongest, best-justined environmental programs in the world.
There are three fundamental reasons why the ozone depletion
program has been a success.
First, the science of ozone depletion is well established. Virtually
the entire international scientific community agrees that ozone depletion is
a severe environmental threat. There is overwhelming evidence that there
is an ozone hole; that man-made chemicals are causing this hole; and that
if this hole is not repaired, widespread ecological damage and harm to
human health will result
Second, the ozone controls established in the Montreal Protocol and
the Clean Air Act Amendments of 1990 are succeeding. We have already
phased-out completely one class of ozone-depleting chemicals, the halons.
At the end of this year, we will complete the phase-out of CFCs. These
controls have been achieved with none of the economic hardship or
dislocation feared when we passed the 1990 Clean Air Act.
Third, responsible U.S. industry supports the ozone depletion
program. The major CFC makers like DuPont and the major CFC users
like the auto companies have already found effective substitutes for ozone-
dq)leting chemicals. Often these substitutes save more in energy-
efficiency than they cost. These U.S. industries want to see the ozone
deletion program successfully completed — they do not want it rolled
back.
I realize that there are some in Congress, including the Majority
Whip Tom DeLay, who want to repeal the ozone depletion provisions of
ibt Clean Air Act. This is simply an irresponsible and extreme position.
Tliose who want to get rid of controls on ozone-depleting chemicals are
for out of the mainstream. They are pushing an agenda that lacks
scientific support, would jeopardize health and environment worldwide,
and is opposed by responsible U.S. industry.
The ozone depletion program has always had bipartisan support in
297
the past. In 1987, President Reagan signed the Montreal Protocol, the
international agreement protecting the ozone layer. In 1990, Congress
adopted title VI of the Clean Air Act, which further accelerated the phase-
out of ozone-depleting chemicals, with overwhelming bipartisan support.
In 1992, President Bush again accelerated the phase-out of ozone-
depleting chemicals in 1992.
In light of this history and the proven success of the ozone depletion
program, ^is bipartisan support should continue today.
298
STATEMENT SUBMITTED BY
DEPUTY ASSISTANT SECRETARY RAFE POMERANCE
DEPARTMENT OF STATE
HOUSE SCIENCE COMMITTEE
SUBCOMMITTEE ON ENERGY AND ENVIRONMENT
SEPTEMBER 20, 199 5
Mr. Chairman, I would like to thank you for affording
me the opportunity to submit for the record the following
statement on the current state of international
stratospheric ozone agreements.
Ozone depletion, a problem common to all mankind,
transcends national frontiers. Man-made compounds have
in recent years posed a threat to the gaseous layer of
the stratosphere which serves to screen out Ultraviolet-B
radiation. Increasing amounts of such radiation only
raise the risk of added cases of skin cancer, reduced
agricultural production and damage to aquatic ecosystems,
etc. The international response to such depletion —
viz., the 1985 Vienna Convention for the Protection of
the Ozone Layer and the follow-on 1987 Montreal Protocol
on Substances that Deplete the Ozone Layer — have been
paradigms of international cooperation.
The Protocol, to which nearly 150 countries have now
acceded, has gained virtually universal acceptance. This
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has been due principally to three reasons: (1) the
excellent scientific analyses which have served as the
underpinning for the adopted control measures; (2)
support among business circles, especially in the United
States; and (3) the creation of the Montreal Protocol
Multilateral Fund in London in 1990. The Fund was
established to assist Article 5 nations (i.e., developing
countries whose per capita consumption of
chlorof luorocarbons (CFCs) was relatively low) to meet
their Protocol phaseout obligations with respect to
ozone-depleting substances (ODS) .
The Article 2 Parties (i.e., developed countries)
agreed to support the Fund because (1) assistance was
limited to the incremental or "extra" phaseout costs; (2)
aid was to be given only to those developing countries
whose consumption of ODS was historically very low; and
(3) the amount of the Fund was a small price to pay to
protect the large domestic investments that developed
countries had made to phase out ozone-depleting
compounds. To date, some $350 million has been disbursed
for more than 800 activities in over 85 developing
countries. When completed, these projects are expected
to result in a one-quarter to one-third reduction of
developing countries' use of controlled ODS. It is
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important to highlight the fact that a number of Article
5 countries, which are currently required to freeze their
consumption and production of CFCs in 1999 and phase out
by 2010, are moving to phase out even more rapidly than
scheduled.
The current situation we now face with regard to the
Multilateral Fund poses major difficulties. The United
States was the major force behind the Fund's $510 million
replenishment (the U.S. share is abut $114 million) for
the three year-period beginning in 1994. We are,
however, now confronted with the situation of being
unable to pay our annual voluntary contributions to the
Fund. As a result of Congressional cuts in State
Department and EPA requested appropriations in previous
years, we are presently some $28 million behind in our
voluntary contributions. Absent appropriations along the
lines of the $51 million requested by the Administration
for FY 1996, it is inevitable that we will fall further
behind. This situation resonates with a certain degree
of irony given our leadership position in developing
technologies that reduce the effects of ODS. U.S.
industry could stand to gain substantially more from
Fund-related activities. For example, a New Jersey
manufacturer has won a $10 million contract for supplying
technologies to help an agricultural concern in the
Philippines phase out its use of ODS.
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The efficacy of and need for the Protocol and its
London and Copenhagen Amendments of 1990 and 1992,
respectively, are beyond question. I would also like to
add that the Protocol and its subsequent amendments were
negotiated by the Reagan and Bush Administrations, both
of which recognized the absolute importance of acting to
assert U.S. leadership in addressing this environmental
threat. In a report entitled "Scientific Assessment of
Ozone Depletion: 1994", the world's leading atmospheric
scientists reported a diminution in the rate of growth of
major ozone-depleting substances in the stratosphere
(i.e., CFCs and halons) . In fact, the scientific
community has observed an actual reduction in levels of
methyl chloroform, another ozone-depleting compound.
In November, approximately 150 nations will meet in
Vienna to commemorate the tenth anniversary of the
Convention, as well as to hold the Seventh Conference of
the Parties of the Montreal Protocol, At this
Conference, the Parties will consider additional phaseout
measures for developing countries with respect to their
production and consumption of CFCs, halons, carbon
tetrachloride and methyl chloroform (i.e.. Annex A and B
substances). In addition, the Protocol Parties will
review developed country obligations with respect to
hydrochlorof luorocarbons (HCFCs) and methyl bromide and
threshold control measures for developing countries for
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the latter two ozone-depleting substances.
At the recently concluded Twelfth Open-Ended Working
Group Meeting of the Parties to the Montreal Protocol in
Geneva, a session designed to lay the foundation for
November's Conference of the Parties, a subgroup of
developing and developed countries presented their report
on additional developing country phaseout measures with
respect to CFCs, halons, etc. The group recommended a
series of scenarios for consideration by the Conference
of the Parties which entail different environmental and
financial costs.
In considering the matter of CFCs, it is also
important to reiterate the fact that no delegation in
Geneva, not even those which are experiencing
difficulties meeting their phase out commitments,
questioned the scientific basis for the phaseout of the
production and consumption of these compounds.
At the Open-Ended Working Group meeting, the United
States continued to advocate the belief that a universal
phaseout for methyl bromide on the part of both developed
and developing countries is perhaps the single most
important measure that can now be adopted to protect the
- 6 -
ozone layer. I note that no final agreement was reached
on the definitions of the methyl bromide quarantine and
pre-shipment exemptions in Geneva. This is a matter of
great importance to American agriculture. We also
broached in a plenary session in Geneva the idea of
establishing a "critical agricultural use" exemption for
methyl bromide. The proposal, which evoked a great deal
of developed and developing country interest, would
permit the post-phaseout use of methyl bromide where,
inter alia, substitutes are neither commercially
available, effective, nor economically feasible.
While the United States stands alone in articulating
the need for an across-the-board universal 2001 phaseout
for methyl bromide, a number of countries such as
Austria, Canada, Denmark, Germany, The Netherlands,
Sweden, Switzerland, etc. have embraced the concept of an
Article 2 country phaseout by 2001. Australia and Malawi
continued in Geneva to support the notion of a developing
country freeze on methyl bromide consumption.
Concerning HCFCs and developed countries, we argued
strongly for the maintenance of the status quo with
respect to both the ultimate 2030 phaseout date and the
3.1 percent cap. While the Nordic nations and the EU
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continued to stress the need to advance the phaseout
date, Australia, Canada, Italy, Japan, South Africa etc.
have gone on the record as endorsing our position. As to
developing countries, we made an equally strong pitch for
an HCFC freeze in 2000 at 2000 levels.
We also succeeded in Geneva in getting the Working
Group to recommend to the Conference of the Parties the
approval of all of our "essential use" nominations for
controlled substances (e.g., CFCs for metered dose
inhalers) .
In considering the foregoing, it is important to note
that in Geneva the G-77 countries and China made it very
apparent that Article 5 countries needed, among other
things, information from the Protocol's Technology and
Economic Assessment Panel (TEA?) on the economic and
financial implications associated with various methyl
bromide and HCFC control scenarios, as well as data on
the economic implications attendant to the remaining
Annex A and B phaseout scenarios. In addition, the
developing countries requested the Multilateral Fund's
Executive Committee to give them a notional indication of
future contributions to the Fund based on currently
agreed control measures. The reports of the TEA? and the
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way to framing the debates and ultimate outcomes in
Geneva.
In assessing the state of the Protocol, it is also
important to cite the fact that Russia and several other
countries with economies in transition (CEITs) lack the
means to meet their CFC phaseout commitments by January
1, 1996. While the Central European nations, according
to a TEAP study, will only have short periods of
non-compliance (i.e., 1-2 years with support from the
Global Environment Facility), the case is very much
different with respect to the Russian Federation and
other nations formerly part of the Soviet Union. In
addition, most of the CEITs have, of late, failed to meet
their voluntary contributions to the Multilateral Fund.
Such contributions are supposed to constitute some 15%
(about $77 million) of the Fund.
In conclusion, the ozone layer continues to
deteriorate. It is imperative, therefore, to meet this
threat. Complacency will only negate the gains made to
date and will only put off further, if ever, the time
when the ozone layer will be restored. A recently
released World Meteorological Organization (WMO) report
cited last week by the Washington Post observes that the
seasonal ozone hole over Antartica continues to expand.
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The report indicates that the hole is now the size of
Europe.
The United States will only be able to maintain its
leadership position in the Montreal Protocol
negotiations, as well as in other international
environmental fora, if we are in a position to make good
on our voluntary contributions. Given the global nature
of the problem, such contributions, relatively small in
size, will redound to the benefit of not only thSv
developing world, but also to the American people.
/
Thank you Mr. Chairman.
307
Appendix 2
answers to questions derived from the september 20, 1995 hearing
submitted to chairman dana rohrabacher by dr. s. fred singer
1. Please list peer-reviewed scientific journals in which you have published.
(Answer) Journal of the Franklin Institute, Physical Review, Physical Review Letters, Reviews
of Geophysics, Journal of Geophysical Research, Transactions of the American Geophysical
Union, Astrophysical Journal, Physics of Fluids, Icarus, Environmental Geology, Environmental
Conservation, Environmental Science and Technology, Meteorology and Atmospheric Physics,
Science, Nature. This is not a complete list; there may also be others. I have published well
over 150 scientific papers.
2. Your name is not listed as a contributor or reviewer in the 1994 WMO Ozone
Assessment. Why is that?
(Answer) It has been the sad experience of many of my colleagues that their critical comments
and objections are ignored by the editors, but that their names are then cited as if they approved
of the Assessment. For example, in the 1990 IPCC Report, the editors explicidy acknowledged
the existence of dissenting views, but then stated that they "could not accommodate them." The
editors did not identify the dissenters, did not reveal how many dissented, nor state the substance
of the dissenting views.
The 7-page list of scientists (exhibited also by witness Mary Nichols as evidence of a
"consensus") certainly looks impressive; but, I would note, there is no way of determining how
many actually agree with the overall conclusions of the AssessmenL
3. You appended to your testimony your recent publication in the Journal of the Franklin
Institute. Does it contain new scientific information?
(Answer) It is primarily an up-to-date review of the evidence, but it also contains some new
information. It points out for the first time that a theoretical paper (by Ravishankaia ct al.) and
an experimental paper (by Wennberg et al.), both published in Science in 1994, lead to the
interpretation that the major destroyer of ozone in the lower stratosphere derives from water
vapor, rather than from CFCs. But water vapor is now increasing, likely because of human
activities.* If this hypothesis is correct, then a ban on CFC production would not achieve the
desired result
4. In his testimony Dr. Watson doubts your hypothesis that increasing levels of atmospheric
methane and carbon dioxide are causing the Antarctic ozone hole. Please comment
(Answer) Dr. Watson misquotes me and is wrong as well. It is generally accepted that chlorine
cannot remove ozone without the presence of ice crystals. Ice crystals require water vapor and
low temperatures. In 1988, 1 published the hypothesis that ice crystals are rate-linuting for ozone
308
removal, rather than just the concentration of chlorine; increasing methane increases stratospheric
water vapor and carbon dioxide lowers the temperature.* Dr. Watson may not be aware that the
same idea was published more recently by Blake and Rowland, without attribution to my earlier
paper.
5. The WMO released a report this month (September 1995) claiming a more rapid increase
in the Antarctic ozone hole. What is your comment?
(Answer) It is generally agreed that the AOH is controlled more by climatic factors than by the
concentration of atmospheric CFCs, more or less as I hypothesized in 1988.* I note, for
example, that the 1994 hole was smaller than the 1992 and 1993 events, but of course there was
no press release. With respect to 1995, 1 will let other scientists speak to the issue:
The latest example of "science by press release" is the scare story about a massive ozone
hole, fed to the media in Sept 1995 by the Geneva-based World Meteorological
Organization. "At its present rate of growth [it] might grow to record-breaking size...,"
said Rumen Bojkov, a well-known WMO alarmist But then again, it might not-
according to NASA scientist Paul Newman. Australian meteorologist Paul Lehmann
agrees: The hole will change its shape, volume, and size daily as it grows; he concludes
that its final size is not predictable by comparing data now with those of a year ago.
6. Please comment on EPA's cost-benefit analysis for a CFC ban, and comment particularly
on the costs and benefits for poorer nations.
(Answer) I am completely puzzled by the unrealistic benefit numbers, up to $32 trillion, put forth
by EPA. The numbers seem to be growing, in spite of the reduced skin cancer threat from a
putative ozone depletion. Their methodology should be presented in detail and then carefully
examined. I suspect that they've not dealt realistically with the number of deaths from melanoma
and non-melanoma skin cancers. I also suspect that they have used an unrealistic discount rate
in arriving at a benefit-to-cost ratio of 700 to 1000.
As far as tropical nations are concerned, their benefits would be close to zero, since ozone
is not predicted to be depleted in the equatorial region. On the other hand, their costs in terms
of morbidity and mortality will be very much higher than in developed countries, since they will
fmd it more difficult to purchase new air conditioners and refrigerators.
7. The American Academy of Dermatology has linked melanoma and the Antarctic ozone
hole Please comment
(Answer) It is true that Dr. Darrell Rigel has testified that skin cancer incidence has more than
doubled since the AOH developed in the late 1970s. But of course, his statement is misleading,
or perhaps even designed to mislead:
• An Antarctic ozone depletion cannot possibly affect skin cancer rates in the United
States, some 10,000 miles away.
309
• Cancers develop only after a latency period of decades.
♦ Melanoma skin cancers have been increasing, by some 800 percent since 1935, clearly
related to lifestyle changes and not to any change in ozone.
8. In his testimony, Dr. Watson claimed that a 1% increase in UV-B radiation would lead
to a 2% increase in the incidence of non-melanoma skin cancers (NMSC). Do you support
this estimate?
(Answer) I believe his result is incorrect. It is derived by noting that the incidence of NMSC
is five times greater in Albuquerque than in Seattle; (clear-sky) UV intensity increases by a factor
of 2.5 as one moves towards the equator. But one cannot simply relate the ratio of skin cancers
to the ratio of UV-B. Watson's high ratio of 2:1 hides two unjustified assumptions: (i) that the
fraction of clear days in Seattie is equal to the number of clear days in Albuquerque, and (ii) that
people in Albuquerque walk around in raincoats rather than short-sleeved shirts and typically get
no more body exposure per day than people in Seattle. When these two assumptions are allowed
for, the skin cancer-to-UV ratio may well drop by a large factor.
9. Please comment on the need and urgency for a production ban on methyl bromide.
(Answer) I have addressed this issue on August 1, 1995, in testimony to the House Commerce
Committee, Subcommittee on Oversight and Investigations. Briefly:
• Methyl bromide (MeBr) comes mainly from natural sources, like the ocean.
• MeBr has a lifetime in the atmosphere of only about 1 year, unlike CFCs. This means
that if a problem arises and production is stopped, the enhanced level will quickly decay down
to the natural level.
• I note that Dr. Watson's testimony constantly refers to "stratospheric chlorine and
bromine." But there is no published evidence I know of that stratospheric bromine is increasing.
The amounts present there are minute and extremely difficult to detect.
10. What would you do about CFCs at this stage of our present knowledge?
(Answer) As I stated in my testimony, I do not have a vested interest either for or against CFCs
or other chemicals. Since CFCs are increasing in the atmosphere, a tax rather than production
controls might be the most appropriate policy measure. A higher price would encourage both
conservation and recycling, and thereby reduce the amounts released into the atmosphere.
"Docs the Antarctic ozone hole have a future?" Eos 69. 1588 (1988)
310
11. You have expressed doubts about the reality of ozone depletion. Please explain.
(Answer) It is difficult if not impossible to remove the natural variations from the ozone record
in order to detect the existence of a small downward trend-presumably due to manmade
chemicals. The attached graph, taken from a research paper by NOAA scientist Jim Angell, tells
the story. It shows the strong, but not perfect correlation between total ozone and sunspot
number, since global ozone measurements were started in 1957. It also shows that each sunspot
cycle is different Unfortunately, it would require ozone data over many cycles to permit the
statistical removal of the sunspot variation from the ozone record and allow reliable extraction
of a small, long-tenn trend.
The lower graph displays another phenomenon: the great variability of the sunspot
maximum over the last 300 years, showing the existence of natural trends lasting for decades.
This means that an observed ozone trend, even if real, may not necessarily be anthropogenic; it
could be natural.
2
0
2
0
2
1 1 1
1
NORTH
\/' ^ ^
POLAR
NORTH
-v/ ' ^-^
TEMPERATE
uj 100
1960 1970 1980 1990
Fi(Brc I. Toul ozone chanjc On %) *<><! snaipoc oninbcr (Antell. 1919).
FipacZ. Aiowal mean unupot nnsber R It ouxinu of (he ll-ycyclc. A.O. 164} >a
present, to deaoosruc lont.iena trendi in solir jciivity. Evident is the IO-ye*t "CleiJJ-
berg cycle" (cxireou ihown « tritn jlej) impojcd on i pcniuent tiie jinee the M»onder
• Minimum.
Appendix 3
Remarks by
Dr. John H. Gibbons
Assistant to the President for Science and Technology
Sound Science, Sound Policy: The Ozone Story
University of Maryland at College Park
September 19, 1995
Good morning. I'm delighted to be here to talk to a group that
includes the next generation of environmental scientists and engineers.
It's appropriate to be talking today to those who will be conducting
research and developing policy in the future because what is happening
now in Washington will shape your opportunities. This is Ozone
Awareness Week and the ozone story is one of the best examples I
know of sound science leading to sound policy. However, at the same
time that we celebrate this success, investments in environmental
science and technology are under attack in Congress under the guise of
balancing the budget.
Achieving a balanced budget is also a priority for the Clinton
Administration. We're in our third year in a new era of deficit
reduction, and that hasn't happen since Truman was President. But this
Administration is committed to balancing the budget while maintaining
investments in the future, in education and science and technology. We
believe that deficit reduction and wise public investment are totally
consistent goals. It's no accident that industries that grew out of
federal investment in science and technology ~ industries as diverse as
agriculture, aeronautics, computers, biotechnology and medical equipment
- today dominate the world's markets. In fact, economists estimate
that over the past fifty years, innovation has been responsible for as
much as half of our Nation's economic growth. Science and technology
are key for a strong economy, for public health and safety, and
improving environmental quality. We must continue a strong commitment
to environmental R&D so we can better understand how the global
environment ~ our life support system - actually works, and how to be
wise stewards of that support system. Over the long-term this kind of
investment pays enormous dividends to the people.
Let's look at an example of one such payoff - the stratospheric
(311)
312
ozone story. I'm sure most of you know what ozone is — a
fascinating, highly reactive, unstable molecule consisting of three
atoms of oxygen. Ozone occurs both near the Earth's surface ~ where it
is a major constituent of smog, and in the region of the upper
atmosphere six to thirty miles above the surface. Paradoxically, while
surface ozone is harmful to human health and the environment, the
"other" ozone - that in the stratosphere - is absolutely necessary for
life.
Research has been key to understanding stratospheric ozone
which blankets the Earth and helps make it a liveable planet.
Stratospheric ozone forms an invisible shield protecting us from the
hazardous ultraviolet - or UV - radiation that streams towards the Earth
continuously from the Sun. UVB radiation can directly harm people.
For every 1% increase in UV-B radiation, there will be an about a 2%
increase in non-melanoma skin cancer in light-skinned people. We
currently have about 750,000 new cases each year in the U.S., of which
between 1/2 to 1% will result in death. Increased exposure to UVB
can also cause cataracts—already the 3rd highest cause of blindness in
the US. Increased UV-B is also associated with decreased immune
system response in all populations.
Without the Montreal Protocol and its amendments (international
agreements to phase out ozone-depleting chemicals), we would be
facing future increases of 40-50% of UV-B in the next century as
opposed to expected peaks of 6-7% in the summer/fall and 13-14% in
the winter/spring.
The story of how we reached these international agreements
began twenty years ago when two research scientists, Mario Molina and
Sherwood Rowland, hypothesized that chlorofluorocarbon molecules
(CFCs) are stable enough to diffuse to the stratosphere where the sun's
ultraviolet radiation would split off the chlorine atom, whereupon each
chlorine atom would act as a catalyst, destroying thousands of molecules
of ozone.
Back then there was little but laboratory data to support the
theory. No one had looked for an ozone hole in the sky- - we didn't
even have the tools to try. There was no long-term record
demonstrating that ozone levels were declining on a global basis. There
313
were no satellite, aircraft or balloon-based measurements of trace gas
species showing the intermediate steps in the process leading to
chlorine-driven destruction of ozone. In fact, all we really knew was
that CFC concentrations in the atmosphere had been rising and that a
seemingly plausible, but unproven, hypothesis existed that chlorine from
CFCs could destroy ozone.
CFCs were invented in the early 1930s as a replacement for
hazardous compounds like ammonia then widely used as refrigerants.
CFCs are odorless, extremely stable, relatively non-toxic and
nonflammable. Not surprisingly their use quickly spread to a wide
range of industrial and consumer applications, from refrigeration to
aerosols propellants to foam products and eventually as solvents in the
electronics industry.
Given the scientific consensus that now exists, it is hard to
imagine the controversy that surrounded this theory two short decades
ago. In part, this controversy was driven by the lack of clear and
convincing evidence in support of the theory, but also largely because
of concern that CFCs were critical to our quality of life and no
substitutes existed to replace them.
How then did we quickly evolve from a politically charged
situation in the late 1970s to today where 150 nations of the world have
agreed to phase-out CFCs by the end of this year in all developed
countries and soon thereafter in developing countries?
First and foremost, this issue has been driven by major and
definitive advances in our scientific understanding. We have gone well
beyond our rudimentary knowledge in 1974 of the impact of CFCs on
ozone chemistry. While uncertainties remain, we are confident about
the atmospheric processes that control stratospheric ozone and the role
that CFCs and other chlorinated and brominated compounds have on
those processes.
The most striking example of this concerns the so called
Antarctic Ozone Hole. When ground-based and satellite data were first
published showing the existence of this ozone hole, which opens in the
Antarctic spring, the scientific community, not to mention the public at
large, were taken completely by surprise. No models or theories had
314
predicted any such phenomenon. At first, the scientific community was
at a loss as to explain its cause. Was it due to CFCs, the result of
some meteorological conditions, or was some other unknown factor at
work here? Was the condition unique to Antarctica, to polar conditions
in general, or likely to affect global ozone levels?
These were more than interesting questions for the scientific
conmiunity to debate. Just about the same time news about the ozone
hole surfaced in the scientific literature, nations were coming together
to discuss what actions they should take to protect the ozone layer.
But a definitive policy decision was dependent on a sound scientific
understanding of the issue.
In what must be considered record time and with broad
international and public and private sector cooperation, two major
scientific campaigns were organized in 1987 and again in 1988 to
collect data concerning the Antarctic ozone hole. Based on extensive
field measurements, lab experiments and modeling, the consensus view
emerged that CFCs cause the depletion of ozone over Antarctica.
This finding brought a sense of urgency to policy makers. As
we all know, ozone is a global issue and requires a global response.
Reductions in the use of CFCs in the United States ~ even though the
United States was the major source of CFCs ~ were not going to solve
the problem if other nations continued to expand their own use.
Subsequently, a series of international scientific studies were
conducted. These reviews began in the 1970s and were formally
brought into the Montreal Protocol when it was signed in 1987. They
have become the bedrock against which policy decisions are taken.
The original Protocol called for a 50% reduction in CFCs by
1998, but also called for periodic review of scientific and technology
issues. The first such review was issued in 1989 and lead to the
Parties agreeing that on the basis of new scientific information that
even greater reductions were needed to protect the ozone layer, and that
chemical substitutes had advanced enough to make practical the full
phase-out of CFCs by the end of the century. I'd like to emphasize that
extraordinary technological progress in developing CFC alternatives by
the industrial sector permitted a faster phase-down. A similar process
in 1992 led to agreement that CFCs would be phased out in the developed
315
world by the end of this year. The recent 1994 international assessment
of the situation confirms the soundness of the science and phase-out
policy.
Let me summarize the evidence that is now very clear and broadly
accepted by experts around the planet:
1 . There is no doubt that the major source of atmospheric chlorine
and bromine is from human activities (e.g., CFCs and Halons),
not from natural sources such as volcanoes or sea spray.
2. There is no doubt that downward trends of stratospheric ozone
are occurring at all latitudes, except the tropics, during all
seasons. Extensive ground-based data and satellite data have
shown that since 1970 ozone has decreased by about 5-6% in
summer and 9-11% in winter/spring in northern mid-latitudes,
and by 8-9% at southern mid-latitudes on a year-round basis.
The weight of scientific evidence suggests that the observed mid-
latitude downward trends of ozone are due primarily to
anthropogenic chlorine and bromine.
3. There is no doubt that the spring-time Antarctic ozone hole is
due to anthropogenic chlorine and bromine — based on combining
ground, aircraft, balloon and satellite data, with laboratory data
and theoretical modeling.
4. During periods of declining ozone, stations in Antarctica,
Australia and mountainous regions in Europe, have shown that
ground-level UV-B increases, as expect
5. The rate of increase of atmospheric chlorine and bromine in the
atmosphere has slowed considerably in the last few years,
demonstrating the effectiveness of actions taken under the
Montreal Protocol and its amendments. Even so, and if
everything goes forward smoothly, the mid-latitude ozone loss
and the hole over Antarctica are not expected to disappear until
the middle of the next century
While the story I have told so far shows science, technology,
and policy moving forward in harmony, I must also report that recently
316
a discordant note has been struck. Amazingly, there are those today on
Capitol Hill who don't want to believe that the ozone hole exists, who
won't trust the evidence of startling observations year after year
showing a hole over Antarctica the size of the United States. Just last
week, the World Meteorological Organization announced that the hole is
beginning to open again, as predictable as Old Faithful. Within a few
weeks, some 60% of the total overhead ozone will be depleted.
Even as the hole opens. Congress is holding hearings tomorrow
to question the science of ozone depletion and the soundness of the
phaseout. Incredible. The scientific community has spoken time and
time again, with a virtually unanimous voice, that the phenomenon is
real, and the problem is immediate and that fortunately, due to early
action, effective chemical substitutes for CFCs are available. Industry
agrees.
Yet, tomorrow. Congress will give a few vocal skeptics equal
standing with the hundreds of scientists represented by the
international assessments. Such ideologically driven attempts to paint
a distorted picture of the scientific consensus on climate change and
ozone depletion are highly regrettable. You can not wish ozone holes
away. Refusing to face the facts won't change the facts. Healthy
skepticism is an essential and treasured feature of scientific analysis.
But willfiil distortion of evidence has no place at the table of
scientific inquiry.
I firmly believe that the American people expect the federal
government to support science and technology so that we can continue
to discover, learn about, and deal with phenomena like ozone depletion.
The American people do not want this country to put its head into the
sand and hope that problems simply go away. They understand that
ignorance is assuredly not the route to our salvation!
Congressional leaders have said they want to fully support basic
scientific research. But their proposals to cut the funds for global
climate change research - including funds for stratospheric ozone
research - suggest their deeds do no match their words. For example,
though over a trillion dollars of insured property along the U.S.
Atlantic coast is vulnerable to sea level rise caused by global warming.
Congress is proposing major cuts in the research needed to help protect
317
this investment. Despite one of the worst hurricanes seasons in
decades, scientific research at NOAA aimed at understanding climate is
targeted for cuts of between 30 and 40%. NASA's Mission to Planet
Earth, which combines satellite measurements with ground-based research
and analysis in the first comprehensive study of the planet we live on,
was slated for a $300 million (25%) cut next year by the House of
Representatives. Fortunately, and due in no small part to the
leadership of your Senator, Barbara Mikulski, the Senate has not gone
along with this extreme action, limiting their cuts to $60 million.
Proposals to eliminate the National Biological Service and the
Environmental Technology Initiative, eviscerate the Superfund research
budget, and slash more than 40% of the funding for energy efficiency
and renewable energy research rest on the same know-nothing stance as
do proposals to gut the effective enforcement of the Clean Water Act
and the Clean Air Act. Unbelievably, just last week Congress attached
riders on to the budget reconciliation bill that would disband all
Department of the Interior surveying and mapping activities by October
1996. If enacted, it would end research on water quality, natural
hazards, land use, and ecosystems. Does Congress really think we don't
need maps to chart our way forward?
Although Congress continues to profess support for regulatory
decision making based on sound science and credible economic analysis,
their actions belie their rhetoric. They say they favor more risk
assessment and cost/benefit analysis, yet they are cutting the very
research programs that provide the scientific information required to do
such analysis.
Not only does Congress not want to know some of the answers,
they also don't want you to know. For example Congress has proposed
to severely limit the public's right to know by limiting expanded
information on chemical releases into communities. We think citizens
have the right to know. The House Appropriations bill for the
Department of Transportation even includes a rider prohibiting the
labeling of tires for rolling resistance so that consumers won't know
which will help them save gas ~ and money.
But we know that lack of information is always more expensive
in the long run. A successful market economy fundamentally depends
318
on the availability of accurate information. We in the Clinton
Administration believe that rather than putting our heads in the sand
and blindly groping for short-term budget savings, we recognize and
protect key investments for the future - investments that are just as
important as debt reduction and will lead to real, long-term
improvements in the economy, environment, health, and security.
Some crises in the global environment, like ozone depletion,
climate change and loss of biodiversity have long time constants— on the
order to decades to centuries to develop and, if they can be reversed,
the time needed for recovery is much longer~on a time scale
somewhere between human and geological time. Political time scales
are more often on the scale of hours to days.
Rene Dubos recognized our focus on fast-changing or short-term
phenomena as one of the great tragedies of humankind. Adlai
Stevenson spoke about Americans in particular as "those people who
never really see the handwriting on the wall until their backs are up
against it." The crises I see developing cannot be solved by ignoring
them. In fact, they will continue to grow worse as long as we refuse to
address them.
Those of you sitting in this room will be part of the group that
must address, and I hope, help us solve these problems. But we today
must assure that you have the tools for that task tommarrow. If our
nation is to be a leader in the 21st century, it must excel in
education, science, and technology. The nations that are able to take
advantage of new opportunities and that can respond to environmental and
economic challenges will be our future leaders. They will be nations
geared toward the future, not the past.
Many members of Congress are acting upon the general
impression that government is inevitably intrusive and wasteful. This
Administration disagrees. We believe that the government can be a
force for good in the life of the nation ~ that government can help
create, for the future, a more perfect union ~ and we will stand by
that conviction no less fervently than the Founding Fathers. The
lessons of stratospheric ozone: scientific discovery and analysis,
innovative technology, invention of substitutes, and diplomatic
agreements of cooperation between governments can combine to avert majo
319
planetary problems. Let us see this episode through successfully and
apply its lesson to the other challenges that beset us. To do less
would be to betray ourselves and our children.
320
EXECUTIVE OFFICE OF THE PRESIDENT
OFFICE OF SCIENCE AND TECHNOLOGY POLICY
WASHINGTON, DC- 20500
October 11, 1995
The Honorable Dana Rohrabacher
U.S. House of Representatives
Chairman
Subcommittee on Energy and Environment
B-374 Raybum House Office Building
Washington, DC 20515
RE: Hearing on "Stratospheric Ozone: Myths and Realities," Wednesday,
September 2, 1995, 9:30 a.m., Room 2318 of the Rayburn House OfTice Building
Dear Mr. Chairman:
The purpose of this letter is to clarify my answer to a question asked by
Congresswoman Rivers before the Subcommittee on Energy and Environment, "Hearing on
Scientific Integrity and Public Trust: The Science Behind Federal Policies and Mandates
Case Study 1 — Stratospheric Ozone: Myths and Realities" on September 20, 1995.
The following paragraphs reflect the text I wish to clarify (currently page 105 of the
printed testimony attached, line 2468):
"... Ms. RIVERS. Before I do that, I would like to ask Dr. Watson, Dr. Albritton,
Dr. Setlow, and Dr. Kripke, if they are familiar with a publication called the Journal of the
Franklin Institute, with what regard that journal is held in the scientific community, and if
they know whether or nor it is maintained in the library of the institution at which they
work?
Dr. WATSON. This is a journal that came to my attention this morning for the first
time. It is not in the library of the White House. It began in 1994, with a circulation of 400
people.
It is obviously in a number of libraries and businesses and a number of institutions.
We understand the circulation is 400.
Ms. RIVERS. Okay. Dr. Albritton, are you familiar with it, or is it in your
institution?
Dr. ALBRITTON. That journal is not in our institution. I'm not aware of it, nor
have I heard it discussed at ozone-related scientific meetings.
Ms. RIVERS. Okay. Dr. SeUow?
321
Dr. SETLOW. I'm familiar with it from my early, early days as a physicist, but I
have not seen it for many years and, to the best of my knowledge, it is not in our institution
at the present time.
Ms. RIVERS. Dr. Kripke?
Dr. KRIPKE. I've never heard of it."
I wish to clarify for the record that the journal Congresswoman Rivers was referring
to in her initial question cited above was, TECHNOLOGY; Journal of the Franklin Institute
not Journal of the Franklin Institute. These are two distinct journals, published by two
separate publishers.
S. Fred Singer's four page commentary titled, "Commentary: the ozone-CFC
debacle: hasty action, shaky science," appeared in TECHNOLOGY: Journal of the
Franklin InstiOite, Vol. 332A, No. 1, 1995.
I have confirmed with Bob Miranda (914) 592-7720 an employee of the
TECHNOLOGY Journal's publisher. Cognizant Communications Corporation, Elmsford,
New York and the Library of The Franklin Institute (215) 448-1200 that TECHNOLOGY:
Journal of the Franklin Institute was first published in die latter half of 1994 and has a
distribution of 400.
The Journal of the Franklin Instimte - first published in 1826 ~ has been in existence
for approximately 170 years, and is as old The Franklin Institute itself - established in 1824
in Philadelphia, PA - the same cannot be said for TECHNOLOGY.
Dr. Setlow's response that he was familiar with the Journal was undoubtedly in
reference to the Journal of the Franklin Instititte not TECHNOLOGY.
For your convenience, I have included the cover page and publisher information for
TECHNOLOGY.
I would like a footnote added to the text of my response directing readers to an
appendix which corrects any misunderstanding about the publication in question.
If you have any questions pertaining to this letter or any other matter, please call me
at (202) 456-6202.
Sincerely,
Robert T. Watson
Associate Director for Environment
323
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GEORGE C. MARSHALL INSTITUTE
1730 M Street. N.W., Suite 502
Washington. D.C. 20036-4505
October 19, 1995
Chairman Dana Rohrabacher
Subcommittee on Energy and Environment
United States House of Representatives
Washington, D.C. 20515
Dear Mr. Rohrabacher:
During testimony before the House Subcommittee on
Energy and Environment on September 20, 1995, 1 was asked to
provide certain information to the Subcommittee, in v*n-iting.
The information requested concerns evidence for a lack of free
and open inquiry in scientific matters related to global change
research.
First, it may be helpful to provide some information on
my background. I received my PhD degree in astrophysics from
Harvard University in 1980 and have been a research physicist at
the Harvard-Smithsonian Center for Astrophysics in Cambridge,
Massachusetts, since then. I am a contract employee of the
Smithsonian Institution; that is, my salary, benefits, overhead,
rent, supplies, support for my scientific experiments, equipment,
etc., including the costs of student researchers, employees and
scientists working on my programs are funded by contracts.
Enclosed is my curriculum vitae; as noted, I am also Depu-
ty Director of Mount Wilson Institute — which has managerial
responsibility for Mount Wilson Observatory — whose physical
plant is worth roughly $70 million. The Observatory is where
the bulk of my research has been conducted since 1980. In addi-
tion, I serve as Senior Scientist at the George C. Marshall Insti-
tute, a nonprofit science and public policy research group. I also
donate considerable cime to science education, especially for
programs helping minority and female students.
I have authored and co-authored more than 125 papers in
the peer-reviewed literature; a list can be provided upon request.
This brief introduction is intended to demonstrate that I
have been successfully competing for scientific funding through-
325
out my professional life. It was thus a great disappointment to learn that scientific
competence is not always the dominate factor in climate change research.
At scientific conferences, conversations on the deterioration of scientific
ethics in global change research are common. I suspect this deterioration reflects
the effect of increased competition for increasingly scarce scientific funding.
Three personal experiences follow:
1. In April, 1990, 1 attended a climate change symposium at Goddard Space
Flight Center, in Maryland. At that meeting I had a coffee-break conversation
with an official in the atmospheric science program of the National Science
Foundation (NSF). I asked for information on the possibility of applying for
funds to study the impact of long-term variations in the Sun on both the earth's
climate and the ozone layer. The research rationale is that the Sun's variations
are one of several natural influences that must be accurately known so the best
estimate of the human-made effects can be determined.
I was told such research would not be considered for funding because it
might raise doubts regarding the importance of anthropogenic influences on the
environment. I was further informed those doubts could have two undesirable
consequences: first, they would give policymakers an excuse to forego mitigation
efforts; second, they would jeopardize the possibility of getting more funds for
climate change research The next day at the meeting, I asked the official to
clarify his position. I was told never to mention the conversation had occurred.
I do not know if the views of one official would actually affect the proposal
process. However, my status as a researcher, who needs successful proposals to
survive, meant I never pursued the matter; and indeed, I never submitted a
proposal to NSF in the area of climate change.
2. Prior to my September 20, 1995 testimony before your subcommittee,
pressure was exerted on me by the advocacy group. Ozone Action. In a July 28,
1995 issue of Ozone Action News, this organization described me as one who
"... gather[s] bad out-of-date studies..." on stratospheric ozone variation. There
was no evidence offered to substantiate of this claim. On September 18, Ozone
Action called the Public Relations Office of the Smithsonian Observatory to ask if
my pending testimony were an official position of the Smithsonian Institution.
The Public Relations Office responded that my testimony was not official.
The next morning, September 19, Ozone Action sent someone to inspect
the 990 taix forms of the George C. Marshall Ir\stitute, in order to determine the
source of funding for my work at that organization. Later that day, the Public
Relations Office of the Smithsoruan sent me a message that Ozone Action had
faxed to that office the cover of one of my Marshall essays on ozone. Ozone
Action included the brief biography that the Marshall Institute provides for the
authors of its reports. My biography included the fact that I am a scientist at the
Harvard-Smithsonian. The voice-mail message from the Public Relations Office
326
of the Smithsonian said Ozone Action was "desperate to link my testimony to
the Smithsonian."
Such conduct by Ozone Action was, I oelieve, meant to engage institutional
pressures on me not to appear at the hearing. The result of this intimidation was
that late on the eve of the hearing, I drafted a letter to you withdrawing from
testifying. The letter was never sent because I decided not to succumb to these
tactics and to appear anyway.
3. My cortfidence in the p)eer-review process has been shaken by an episode
involving the editors of the journal Nature. In October, 1992, my colleagues and
I submitted a manuscript to Nature on work relating to changes in the Sun,
which might have impact on terrestrial climate change. The manuscript re-
ceived treatment unprecedented in my 15 years of experience. Briefly: The paper
was held in the review process for 14 months and apparently went through five
different referees and three different editors. After two referees accepted the
paper, the editors kept trying until they found a referee who would recommend
rejection. This violates Nature's stated policy of accepting manuscripts approved
by two reviewers.
Even more indefensible, one reviewer suggested our resiilts were a direct
consequence of my funding from a foundation supported by an oil company.^
The clear implication was that I had doctored my findings to please a corporate
interest. This was a mere assertion, however, since the reviewer offered no
evidence to support this attack on my integrity. Yet the attack was implicitly
accepted by Nature's editors since it was forwarded by them to us without
comment or disavowal.
After this shameful episode, we submitted the manuscript to the most
prestigious journal in astrophysics. The Astrophysical Journal. The Astro-
physical Journal accepted it for publication immediately.
The lack of editorial objectivity in some scientific journals, as I have
described briefly, raises questions about the peer review process. Enclosed is a
p>erceptive comment on this matter by Dr. David Goodstein, Vice Provost and
Professor of Physics and Applied Physics at Cal Tech, which recently appeared in
The American Scientist. He describes the breakdown of the peer review process
as a result of increased competition for decreasing research funds.
The situation has deteriorated in the last year. In September, 1994, a press
statement released by Intergovernmental Panel on Climate Change (IPCC) offi-
cials stated that "The world's climate is at serious risk." This press statement was
drafted before the meeting of the panel of scientists advising the IPCC at which
'The particular choice [of analysis] made in this paper, and its implications for the global
warming debate, may be considered desirable by some of the sponsors listed in the
acknowledgements, but it is not science." Anonymous reviewer for Nature, December 31,
1993.
327
the findings referred to in the press statement were supposed to be disctissed. In
violation of IPCC rules, the scientific drafts had not been distributed to partici-
pants prior to the meeting. The scientists on the IPCC panel were not even
informed of the existence of this IPCC release beforehand, although it nominally
represented their opinion. An editorial in Nature ^called this "commurxication
by press release" and "a rotten way to conduct international business."
In December 1994, a conunentary in Nature ^referred to the "rapid politi-
cization of the climate debate" and concluded, "Under pressure, even scientists
will deliver what their paymasters prefer to hear."
As you see, my experiences are a part of a much larger problem. I hope this
information, requested by the Subcommittee, is helpful.
Sincerely,
Sallie Baliunas
Enclosvires: Cvuriculum Vitae
American Scientist commentary on deterioration of peer review
Nature editorial on IPCC press release
Nature commentary on politicization of climate change research
Z "IPCC's ritvial on global warming," Nature 371, 269 (1994).
3. Nature 372, 402 (1994).
328
SALLEE BALIUNAS, Astropiiysicbt
ACADE\aC APPOINTMENTSj
19%0-preseni
\9S9-present
1990
1980
EDUCATION:
1980
1975
1974
Astroidiyricist, Smithsonian Astrophysical Observatory
Adjunct Professor, Center of Excellence in Information Systems
at Tennessee State University
Visiting Scholar, Dept of Physics and Astronomy, Dartmouth College
Reseaseb Associate of Harvard College Observatory
Ph.D. Harvard University
A.M. Ibrvaid University
B.S. Villanova University
HONORS AND PRIZES:
1993-1994 Wesson Fellow, Stanford University
1988 Bok Prize. Harvard University
1988 Newton Lacy Pierce Prize, American Astronomical Society
1987 Villanova University Alumni Medallion Award
1980-1985 Langley Abbot Fellowship, Smithsonian Institution
1979 Donald E. Billings Award in Astro-Gcopbysics, Univ. of Colorado
1 977- 1 979 Amelia Earbeait Fellowship, Zonta International Corp.
OTHER APPOINTMENTS:
1991-present Deputy Director, Mount Wilson Institute
1969-pnsera Member, Board of Trustees, Mount Wilson Institute
1993-prejrenr Board of Directors. Astrooomic&l Society of the Pacific
1993 Committee of Visitors, Astronomical Sciences, NSF
1992-pr«CT»/ NSF Advisory Committee for Astronomical Sciences (ACAST)
1992-1993 Ptar Review Panel on Carbon Dioxide Limits for Tennessee
Valley Autfaority
1992-prgsent NSF-RKE (Radiative Inputs from Sun to Earth) Steering Ctte
1990-1993 NASA Science Operations Management Operations Working
Qioiq) (SOMOWG)
1987-91 Chaitman, Sdeooe Advisory Board, Mount Wilson Institute
1 984- 1 987 AURA Observatoiics ' Visidng Committee
International Ultraviolet Explorer (lUE) Satellite
1985-87; 1989-92 Users' Gotnniiltee
]9^i-present Guest Invcstigalor
1989-1990 Sciendflc Oigwuzing Committee, NASA/ESA/SERC
lUE Synyosium. Toulouse, Prance
329
Automaiic Photoelectric TeUscopeJ (AFT)
l9iS-preserU Organizer, 3nl and 4th Summer Workshop
\9i6-present Science Advisory Panel, Smithsonian-Faiibom Observatories
1988-1991 Co-otsanizer of 9th, iOth, 1 1th IA.P.PJ». Symposia
Editorial, Educational and Other Advisory Appointments
1993-prtsent Chair, E^iotial Board, Publications tf the Astronomical
Society of the Pacific
1 99 M 994 Editorial Board, Solar Physics
\99Z-present Organizer, Smitltsonian Institution Associates Annua]
Expedition to Mount Wilson Observatory
1991-prf5«n/ Chair. Science Advisory Board, George C. Marshall Institute
1992-1993 Scientiflc Organizing Committee, lAU CoUoq. 143, Solar
Irradiance Changes
1992-1993 Organizer, American Association of the Advancement of Science session,
What Attropkysics Can Tell Us about Climate Change, Boston. MA, 1993
1992 Guest Editor. Annual Review of Astronomy and Astrophysics
1993 Scientific Organizing Committee, Optical Astronomy from the Earth
and Moon, lOSdi Meeting of the Astronomical Society of the Pacific.
San Diego, CA.
1989-1990 Science Advisory Board, George C. Marshall Institute
1992 Editor, Proceedings of Robotic Observatories Symposium
1989-1990 Science Panel, Astronomy and Astrophysics Survey Connnittee
(J. Babcall, Chairman)
1989-1990 Co-Chair. Scientific Organizing Conunittce, 101st Meeting
AstrowMnical Society of the Pacific, Boston, MA
1989 Chair. ROSAT X-ray Satellite Peer Review Panel. Hot Stars
1987-1992 Astronomy Committee. Maria Mitchell Observatory
\W1 -present SYNCM" Steering Coraraittec, NOAO
\9i5-presera Lecturer, Smitlisonian National Associate Program
\S9\ -present Advisory Board. Learning Technology Center, Vanderbilt
Univenity
1984 Editor, Proceedings of the Third Cambridge Workshop on Cool
Stars, Stellar Systems and the Sun
1981,1983 Organizing Committee, Cambridge Cool Stars Workshop n. m
PROFESSIONAL SOCIBTIES:
American Astronomical Society
American Geofriiysica] Union
American Physical Society
Astronomical Society of the Pacific
International Astronomical Union
Sigma Xi
Solar Physics Division, American Astronomical Society
P. 07
330
M.\>. i.( A^I^H't
Peer Review
after the big crunch
David Goodstein
According to modon cosntalogy, the uni-
verse began about 10 blUlon years ago in
an event known as ths Big Bang. It has
been expanding ever since. VSfie do not know
whether it will go on ei^andlng forever, li the
density of matter in the universe is suffidentiy
lai;^. gravitatioru] (oroe* wUI eventually cause it
to stop expanding and tfi«n to start filling back
in upon itself. U that happens, tine universe will
end in a second catadytinic event Aat cosmoki-
gists call the Big CncKK
I have a rather anaiogov* theory of the histt>ry
ot science. According to thia theory, modem sd-
erwe appeared on the scene in Exirope almost 300
years ago, and in this coontry a littla more than a
century aga In each case it prooeadcd to expand
at a frightening exponential rate The phenotne-
ncw is shown on Figiue 1, a eemt-logarithinic plot
of number versus year. The upp«r curve, first
published around 1960 by Derek da Solla Price,
shows the cumulative nmnber of scientific jour-
nals founded worldwide. For 200 vears, from
1750 to 1950 (when the plot was ir»<te) the num-
ber increased by a factor of 10 every 50 years, ex-
trapolating to one million today (there are actu-
Dmui L Caodsltin is vie* pnsaH *iti fnfaaai ofpltyiia and
tpplitd ^ytit$ M Iht OJifomit liutUtiHofVKluiolag^, ahcrr
ht ku btm m Ihe /araltif for mart Uxm IS yon. In 1995 he
lull rwmnl iks Trmnk I. GlUoan DHHngialtBl Ttanhlitg tnd
Savin Pnfaior. H«« Ihtnlharafmair Hmn 100 nrxnortur
IkksMdthtbookStatmofMtmt.piMhiitiim l975byPtm-
Itce Hull and rciuiieiliyDootT Plot in 7985. Hf ArMtmwion
Kiimtrvus KitiKt ami aadanie fmndt, indydlns Hic SnuuUng
Rti'Inr Board of lilt KKiTUescofttod ttm CommHm on Eifual
OpporlHitiites in Scrcncr gnd EMfinerring, a Ntrtional Science
tmniLiiiiin ontiiglii eemmiUte- HtitOie hoti ami pnietl A'-
rcKlor of "The t'lfChankitt UnivtrM." ait atemrd-tri/rnmg and
fuuitf/y uud 52-iKirl caUtgt phynfc* tdttoune koni on Ais pa^
ular lecltirts at Calltdt. AMrtU: OgieeoftlK Pmmt. Caltedt.
PaMdoiii.CA 91123.
ally about 40,000). To check Price's assertion that
any measure of the size of science would have
the same brfiavior, I have plotted on the sanw
scale a« number of Ri.D.'s granted in physics in
the United States- That started around 1870, and
grew even bster for 100 yeari.
Exponential expansion cannot go on forever,
and so the expansion of science, unlike the ex-
pansion of the univeree, was guaranteed to come
to an end. I believe tiiat in American scienoe, the
Big Crunch took place about 25 years ago — after
two decades ^t saw the enormous postwar ex-
uuu.uuu -
/
/
/
100,000 -
/
«>«
/•
/•
10,000-
scientific journals »^
•/
/
^ • .
1,000-
^ *••••
/
/ " .•
/
100-
4 •
r
10-
. ..^
,• • / U.S. Ph.O'a In phyiics
• / <pwy«^
1-
f , . .■ ,
1800 1900
year
Figtu* 1. Th* cad of Sciowc'c Big Bug.
199S Seplxwber-Oadbtf 401
P. 08
331
pansion of acMlemia and Itw OMtion of eotpo-
rate and govanunent rtMaxch bboratoria* all
around ihc US. in rcapoftM to •oonoBik growth
and the Cold War. Tht^ood tliM|>«nded forever
arotmd ^970, w one can Mt from the grapK By
importing ttudents and amploylng Fh-D.'s as
temporary posidocs, wAhawflMtcKed tinw out,
pntending that notMnghaa dunfetd' wailing for
the good time* io return. For a quarter-century
we ha ve been trying to lgnoi« fl«e end of the
great expansion of AiMdean idenee. What we
have to do now is iotv» a pioblann that h«> never
even occurred to the OMBlologlM: What do you
do jfter the Big Crund<7
The crisea moat taUoad about a>« the shortage
of jobs and reacardi funda. Bttt they are jtist the
beginning. Under lUaw from dioae problem*,
other parts <rf ^ tdanttflc enlerpdae have start-
ed showing signs 0^ dlabaH. Ot« of ttte most es-
sential U the aurttei of liiancaiy and ethical be-
havior 
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